Sodalite Mining Project

SODALITE MINING PROJECT ENVIRONMENTAL IMPACT ASSESSMENT FOR MINING OF BLUE SODALITE DIMENSION STONE, RARE EARTH ELEMENTS AND IRON ORE, NEAR OTJIMUHAKA, WITHIN MINING LICENCE 40 & MINING CLAIMS 68664, 70783, 70784, 70113, 70114, 70119, EPUPA CONSTITUENCY, KUNENE REGION

SCOPING REPORT WITH ASSESMENT

Prepared by Philip Hooks April 2021

Project: Environmental Impact Assessment for mining of blue sodalite dimension stone and other minerals, near Otjimuhaka, within Mining Licence (ML) 40, Epupa Constituency, Kunene Region

Report: Final Report for Submission to MEFT, version 6 Version/Date: 24 April 2021

Prepared for: KNL of Namibia (Pty) Ltd

Cite this Hooks, P.N., 2020. Final Scoping Report with Assessment for mining of blue document as: sodalite dimension stone, Rare Earth Elements and Iron Ore, near Otjimuhaka, within Mining Licence (ML) 40 & Mining claims 68664, 70783, 70784, 70113, 70114, 70119, Epupa Constituency, Kunene Region

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

EXECUTIVE SUMMARY KNL of Namibia (Pty) Ltd, (hereafter referred to as KNL or the Proponent) is a wholly owned Namibian company, which holds the mineral rights as granted with ML40, issued by the Ministry of Mines and Energy on 24 April 1997. KNL plans to continue mining sodalite as ornamental and dimension stones and also start mining and processing of other minerals within Mining Licence 40 (ML40) and within nearby Mining Claims 68664, 70783, 70784, 70113, 70114, 70119 that the proponent currently has rights too. All mineral rights are located at the northern border of Namibia. in the Kunene Region. The proponent appointed Philip Hooks, an independent Environmental Assessment Practitioner (EAP), to undertake the assessment and compile this scoping assessment report and Environmental Management Plan (EMP) in support of the application. The curriculum vita of the EAP is provided in Appendix A. From 1997 to 2006 the company developed dimension stone quarries within ML40 together with the related mining and processing infrastructure at the accessory works area of the ML. Since 2017 no blocks of dimension stone have been extracted. Plans to expand the mining to iron-titanium ore and to rare earth minerals have been drawn up. The accessory works area will be expanded to accommodate the processing of these additional ores. The Terms of Reference for the proposed project is based on the requirements set out by the Environmental Management Act (EMA) (2007) and its EA Regulations (2012). Mining will take place within the licences, which cover approximately 730ha and which lies roughly 130 km north of Opuwo and about 2.5 km south-west of the Namibian-Angolan border, marked by the river Kunene (see the map below). The ML40 area is situated 4 km south-west of the settlement Otjimuhaka (previously Swartbooisdrif) (see Figure 2 in the report).

The proposed activity focuses on the specific resources of sodalite, iron ore and rare earth mineralisation. The activities will be undertaken in phases as follows: ➢ The construction phase activities ➢ The operational phase activities

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

➢ Decommissioning phase activities Operation will entail mining, i.e., drilling and blasting of rock outcrops and also open cast mining with diamond cutting equipment to extract industrial size blocks of dimension stone. Mining techniques will make use of modern equipment such as excavators, diamond wire saw, circular diamond cutting machines, compressor driven drill rigs, jack hammers and dump trucks. Open cast mining will be established according to good industry practice procedure. KNL wants to establish central processing facilities for dimension stone, iron ore and for rare earth mineralisation, all of which occur within the Mining Licences and to some extend also on other surrounding mineral licences. Blocks of dimension stone, lumps of ornamental stone or concentrates of base and rare earth metal products are to be transported as bulk cargo as well as in bagged form. The viability of any mining operation, just like most industries, is particularly sensitive to the logistics concerned with getting the product to market. Different options are presently being investigated for the transport of the products to the harbour of Walvis Bay. Bulk bags on low-bed trucks or bulk road transport with loads up to 67 tons are envisaged to take the products on the public road infrastructure from the mine site to the harbour of Walvis Bay. Various studies have been undertaken to support the usage of such trucks including road wear analyses, modelling of a tractor-trailer design, bridge assessments. Product will be transported on a continuous basis. At a maximum monthly production of 5,000t a total of 139 truckloads at 36 t would be required. That is 5 trucks each day. The product would be transported along the gravel road to Ruacana and thereafter along the tar roads to the port of Walvis Bay. The mining licence is situated in a remote rural area. The physical and biological environment is aesthetically beautiful. There are obvious signs of degradation by previous mining activities and the effects of the current drought exacerbate the difficulty that the communities experience in living off the land. The mining operations take place on communal land. Due respect is given to the communities that use the area for subsistence living. The Ovahimba people are semi-nomadic and may come near the mining operations from time to time. Good community relations are imperative for the successful running of the mine. Public safety is of utmost importance. Decommissioning activities will include the removal of infrastructure, preparation of final landforms for closure and to rehabilitate roads where necessary. However, ongoing rehabilitation and landscaping should be conducted as the mining operations proceed. Shaping of the excavated area not only to accommodate rehabilitation efforts, but also in terms of safety, should be conducted according to a rehabilitation plan. In accordance with the Environmental Management Act, the proponent is required to make funds accessible which will specifically be available and allocated for rehabilitation efforts. This fund should continually be available during the life of mine yet also be sufficient to cover the decommissioning activities as required. The potential impacts associated with sodalite mining are specifically outlined in the environmental impact assessment chapter and incude the potential impacts on personnel working at the mine and the public who might reside near the mine. If purely looking at the available rock material within the mining licence, the estimated mining lifespan could be more than 50 years. However, for this assignment an estimated mining lifespan of up to 25 years is considered. The life of mine for the operations has been based on the expected demand and the size of the resource. However, this may vary significantly as the demand may fluctuate. Public Participation Public consultation was thorough, and the communities were well informed about the project. This was done through newspaper adverts for two consecutive weeks in The Namibian and Die Republikein (21st and 28th of July 2020) as well as face to face meetings with the public and relevant authorities. The stakeholders had an opportunity to ask questions and raise their various concerns. Upon completion of this report and drafting of the environmental management plan the Interested and

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Affected Parties have had further opportunity to provide input during the public review period. During the public review period (21st March to 19th April 2021) the community and regional stakeholders were engaged in a second round of face to face meetings (29th and 30th March 2021) to give feedback on the outcomes of the studies and impact assessments. All the documentary evidence for public participation is given in Appendices B to H. The following table lists the main issues that were raised in the first and second phase of the public participation process. Responses are given and references are made to the various sections and documents that provide answers the questions that were raised during the first and second round of meetings. These are the main points or concerns. Other issues are recorded in the minutes of the public meetings in Appendix G.

Theme Issues & Responses (First Round of Meetings)

Issue: Various requests for infrastructure improvement, provision of training, Corporate Social Responsibility programmes and other benefits to flow from the proposed mine to the local community and conservancy.

Benefits to the local 1 Response: Section 6.7 and Table 28 deals with socio economic community impacts. Direct and indirect benefits are discussed in these sections. The proponent will make the final decision on what type of social responsibility project (s) could be funded or developed. The results of the NBRI botanical survey will feed valuable conservation status of plant species back to the conservancy for promoting the special endemism of the area. Issue: Concerns about local people being negatively impacted, by e.g. the tailings dams, dust, radiation, contamination of groundwater, and solid wastes. Mine infrastructure, 2 processes and Response: Section 4.5.1.2, Section 4.5.1.3, Section 4.5.1.4, Section developments 4.5.1.6, Section 6.3 and, Table 17, Table 18, Table 20, Table 21, Table 24, and Table 23 discuss each of these matters in detail. The EMP will provide the legal responsibilities for these aspects.

Issue: Concerns about the deterioration of the roads that will be used by heavy vehicles, and its impact on tourism.

3 Negative impacts on roads Response: Section 4.5.1.5 and Section 4.5.2.2 and, Table 17, Table 22, and Table 29 provides decriptions of how the proponent will tackle these issues. The roads and bridges will maintain their integrity under the payloads planned and the frequency of trips.

Issue: Request for proper avoidance of sacred sites when planning the various infrastructure components of the mine. 4 Heritage issues Response: The results of a survey can be found in Appendix N. The impact assessment is based on this survey.

Issue: Enquiries on the plans to rehabilitate, and on the permanence of the proposed quarries. 5 Mine rehabilitation Response: Section 6.6, summary of the flora and fauna input provides background information on the need to provide for rehabilitation of disturbed areas. Table 25 and Table 27 provide

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

the assessments for the biodiversity and water resource aspects. These impact assessments require the drafting of a rehabilitation and mine closure plan. Some quarries will leave permanent scars in the landscape. Some smaller excavations like trenches will be refilled with waste rock but this cannot be done in all cases. Action will be necessary thereby ensuring larger quarries are made safe.

Issue: Enquiries regarding opportunities for small-scale mining or value-addition (eg gemstones) opportunities for the local Value-addition community. 6 opportunities Response: The proponent will need to respond as it is beyond the mandate of the EIA to answer this question.

Issue: Concerns about the negative impacts on local people and traditions, caused by work-seekers and entrepreneurs attracted to the area.

Response: There will be pressures on traditional ways of life, understandably but it will not be the intention of the mine to change 7 Social disruptions the ways of the community. It will be necessary for the leaders of the community to resist the affects of the outside world on their traditions. Any secondary services that would want to start local businesses in Oroutumba or Otjimuhaka would need to get permission from the local authorities to operate such businesses. It will be beyond the authority of the proponent to control these aspects.

Issue: Requests for thoroughness, including liaison between the biodiversity specialist and local MEFT officials. 8 Biodiversity impacts Response: The fauna and flora specialist attended the meetings and made recommendations to include NBRI in the flora survey work that will be part of the EMP requirement.

Issue: Requests from various authorities for compliance with eg Forestry permits, land and fencing authorisations, road developments, internationally shared water requirements.

Response: The biodiversity specialist and water specialist made 9 Permits and authorisations references to these requirements in their reports. See Table 25 on the biodiversity assessment, Table 26 and Table 27 on water impact assessments, chapter 3 for legal requirements and chapter 6.4 for water quality requirements Fencing will be confined to small areas for security and public safety purposes.

Issue: Enquiries about the process and timeline for giving inputs, the proponent, and the need for transparency.

Response: The public participation process requires that the public are informed about the project. Form the notification of the project 10 EIA process the public have had the opportunity to give input into the process. This report and all the specialist reports have been printed and placed in the Kunene Regional Offices in Opuwo and at the Otjimuhaka Primary School Office. All registered interested and affected partiesh have an opportunity to review these documents and provide input before the final submission to MEFT. Mr. John

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Pallet will summarise the findings at a public meeting during the public review period.

Issue: Requests and suggestions from the local community for ongoing feedback and liaison Further consultations with 11 the local community Response: The proponent will continue to interact with the local community using the channels it has already developed.

Issue: Concern about impacts on local livestock farming.

Response: It is the proponent’s intention to allow livestock farming 12 Local livelihoods to continue as before. The only time the shepherds need to stay away from the mining area’s 500m radius will be during blasting periods. Ample warning will be given.

Issue: Concern about conflicting land uses with eg the conservancy and livestock operations. 13 Land use Response: The proponent will endeavour to remain at peace with all parties.

Issue: Clarifications on neighbouring mining operations, and the importance of environmental and social considerations in planning. 14 Miscellaneous Response: The proponent will not interfere with other operations in the area.

Theme Issues & Responses (Second Round of Meetings - Feedback)

Issue: Will future mining activity expand into new areas that have not been used up till now?

Response: Sodalite and rare earth element mining is planned as a very small-scale, private mining operation. Its footprint will be like 1 Mining Areas that which was established during mechanised sodalite mining at Ondoto in the past. It is planned to only mine about 10,000 to 50,000 t of ore per year (Rössing mines this amount in half a day). The map below shows areas where mining will potentially take place on ML40 and the mining claims. (Figure 2)

Issue: Concern about radioactive minerals – how much of a risk will they pose?

Response: There are only low concentrations of naturally occurring deleterious or radioactive elements associated with the sodalite and rare earths ore. Within the rare earth elements (REE) ore, thorium is contained in a low concentration of about 0.0024% thorium per 1% 2 Radioactivity REE. To put this into perspective, the REE ore contains only about 1/10 of the thorium of the active rare earths mine at Mountain Pass in California (USA). (Section 6.3.3.5 and impact table Table 27) If in future during further beneficiation and value addition in Namibia, the threshold for controlled radioactive minerals is exceeded at any point, a radiation management plan will be developed and, after approval by the Radiation Protection

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Directorate (MoHSS), implemented as at other planned rare earths or uranium mines in Namibia.

Issue: Well-being and livelihood of local community members. Will they still be allowed to do small-scale mining and marketing of sodalite, as has happened in the past?

Response: The small-scale miners (SSM) may mine on pre-approved areas within ML40 and the MCs. The following modus operandi was implemented last year by KNL to accommodate and improve the sales and marketing of sodalite: 1) All high quality “super” sodalite is bought on site from the SSM daily. 3 Community Livelihoods 2) The B1 and 70/30 sodalite qualities are sold by the SSM to Namibian, South African and Chinese customers and KNL oversees the administration and the fairness of these transactions. 3) KNL assists the SSM by constructing their mining sites and commence their activities.

KNL currently supports 10 pre-approved groups consisting of both, women and men. Each group consists of between 5 to 10 self- employed miners. Current total is 65 self-employed miners.

Issue: Community appreciates the infrastructure improvements. But these are only being established because the mine needs them, so it is not altogether fair for the company to boast that these are signs of generosity that the community should be grateful for. The community sees others getting rich from the resources in their area, and genuinely wants to know what benefits will flow to them. Will there be any royalties to the local community? On commercial farms there is a recognised owner to deal with; the situation is different on communal land. Benefits to the community are often ignored or abused. Any opportunity for shareholding by local community members?

Response: So far no one has become rich from mineral resources in the Kunene Region. To the contrary, hundreds of individuals and companies have invested large amounts of money to explore for 4 Community Benefits mineral resources, but these investments never paid back as no significant mining operations could be run profitably. The inclusion of the rare earth element mining is a highly risky investment by the shareholders and the capital expenditures have to be paid back to banks and investors. Once the mine is producing it will have to pay royalties to the Government of Namibia and other taxes and levies. These tax payments ensure among others, that pensions for the elderly at Otjimuhaka and salaries are paid to teachers, nurses and the police. Therefore, the local community and Namibia at large benefits if a profitable mine can be established. Management and personnel of the mine have a well-regarded track record of cooperation projects with local communities at all levels at other operations. (Section 6.7.3 and Table 28)

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

From day one, the company sourced its work force preferentially from the local community in the Otjimuhaka area. This will be further enforced when the exact numbers and skill requirements for new staff at the mine are defined. Furthermore, the company put in a big effort to support the local sodalite miners, to legalise their activities, to give support with mining and mining equipment and marketing of their products which will continue for the next years. Once production has started and it can be foreseen that the mine will be profitable, a committee will be established to explore how the local community can be further supported with practical projects which help to create a sustainable future at the mine.

Issue: How many people will the mine employ, broken down into categories unskilled/semi-skilled/skilled. Community concerned that mining has already started (eg clearing of the Acc Works Area), even though mining has been stopped until the ECC is issued.

Response: The employment of people is dependant on the phase in which the company is in. (See Section 6.7 and Table 28) The self-employment on the sodalite mining is envisaged to create up to 100 employment opportunities for unskilled labourers within the community in the future. 5 Employment Opportunities For the REE mining the below table categorises, by phases, what the envisaged employment could be:

Phases Unskilled Semi- Skilled Total Skilled

Exploration 25 - 35 25 - 35 15 - 25 65 – 95

Development 25 - 35 35-55 25 - 35 110 – 125

Production 15 - 20 20 -30 10 - 15 45 – 65

Issue: Mistrust that KNL is trying to favour certain chiefs / headmen. There were long discussions around who are the recognised leaders, who needs to be consulted and who grants authorisations.

Response: KNL engaged with the community through two leaders, the chiefs Ngombe and v d Merwe, who are both the Government recognized and gazetted official headmen for the project location. This is the accepted best-practice approach of interaction with 6 Community Relationships communities. After several meetings with the community, it emerged that leadership in the Otjimuhaka community is not entirely solved. It seems a large portion of the community disputes the roles of the two headmen above and supports Mr Tjindunda Muhiamo as their leader. The company recognizes and respects this. KNL will require the community to present a clear leadership structure for further communication and decision making. A consent letter from the Chief Ngombe is recorded in Appendix G.

Issue: Accommodation arrangements for mine staff are not 7 Infrastructure development addressed in the EIA. How many people will be housed? Where? These facilities need to be included and addressed in the EIA.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Regional Council needs to be made aware if this will become a larger or more formalised settlement / village. And to make provision for eg sewage, other facilities.

Response: KNL does not want to expand the existing settlement near the existing mine site. Middle and senior management employed by the mine will be accommodated at the Kunene River Lodge approximately 10 km distance away from the project site. Besides the existing accommodation at the current mine site, which is a single house, only approximately 10 additional housing opportunities will be required at Otjimuhaka village which will be adsorbed by the local housing market.

Issue: It is important that the mine should leave a lasting, positive legacy. Skeptical that almost all the impacts are rated as Low after mitigations – can this really be true? An important principle in environmental law is ‘polluter pays’. This should be properly applied in this case.

Response: KNL is fully aware of the provisions of the Draft 8 ‘Polluter Pays’ Principle Environmental Management Plan (EMP). The company will closely monitor potential impacts and implement mitigation measures laid down by the Environmental Assessment Practitioner (EAP) in the Draft EMP. KNL is convinced that the EAP and Specialists have undertaken a thorough process for all studies and reporting documents. A low significance can be achieved provided the measures are implemented.

Issue: The retaining walls downstream of the Accessory Works Area don’t look practical. Will the containment dam contain all the runoff? – the way it is depicted, it does not look like it. There needs to be independent monitoring of the water quality downstream of the Tailings Storage Facility.

Response: The company will ensure groundwater resources are not 9 Surface & Ground Water negatively affected by runoff. A monitoring borehole in the local stream will be sited downstream of the Accessory Works Area and will be sampled to analyse the water quality. No independent monitoring is conducted by government. Industry practice is for the mine to monitor in accordance with the provisions of the Draft EMP and report to the Department of Water Affairs on a regular basis. Water and effluent disposal permits are due for renewal every 2 to 5 years. (See section 4.5.1.2 , section 6.3.3 and Table 27)

Issue: Nearest household to the Accessary Works Area is only 250 m away. Seems very close. How can we be sure they will not be affected / compromised by the development?

Response: The Radiation Protection Authority needs to give their approval to the safety of the operations and whether any relevant 10 Proximity of Residences limits are being exceeded. A baseline assessment of houses and their residents was conducted in 2020 (Section 6.7.6). While no inhabitants could be found in the wider surroundings of the planned mines and processing plant, an abandoned, seasonal hut structure of Mr Mberikuatisa Ngombe exists near the Accessory Works Area. The existing structure was

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

documented by drone images and photographs (Figure 35). If this hut serves temporarily as homestead, the actual impact by noise, light or dust will be assessed, based on which alternative sites for the hut structure will be considered.

Issue: Roads Authority needs to be consulted re junction with the proclaimed road, signposts, crossing of the pipeline over the river road, any activities within the road reserve. Also, condition of the road to Opuwo is poor in many places, esp bridges. This situation will need to be improved before heavy transport truck traffic can commence. 11 Road Usage Response: The public participation process ensured that all stakeholders were consulted including the Roads Authority of Namibia. KNL will engage with the regional head office of the Roads Authority in Oshakati that is responsible for the Kunene Region to discuss any transport related matters.

Project Screening At the start of the project, and confirmed through site visits and public participation, aspects of the envisaged mining project were evaluated for their need to conduct in-depths assessment. This screening determined the terms of reference of the impact assessment phase. Based on the screening, specialists were commissioned to undertake baseline studies and impact assessments. The outcomes of the mitigated impact assessments are tabulated below. A summary statement for each impact assessment is also provided below. This report is thus the product of the shortened EIA process and is referred to as an Environmental Scoping Report with Assessment (ESR). Based on the final screening process, the following specialist studies were included:

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

1. Biodiversity studies (Fauna & Flora) by Mrs. Henriette Potgieter (Appendices I & J) 2. Water Studies by Namib Hydrosearch cc (Appendix K) As part of the water study the hydrogeology componentincluded geochemical analyses and element mobility assessments of the ock and soil as this is key to understanding potential pollutant flow. Water supply to the project and flood water management are also major components of the water studies. Alternatives for the various aspects of the envisaged development were discussed with the individual specialists. Based on their input, with due consideration of the comments received by the public and stakeholders and also the proponent’s development plan, the options were described. These options were weighed in the assessments phase. The preferred project alternatives have been fixed as follows: ➢ The abstraction of water from a site that constitutes Kunene River infiltrate (i.e. alluvial sediments or dwyke sedimentary rock) as the major water source for mineral processing. ➢ The abstraction of water from the Ondoto River as a minor source for mineral processing. ➢ The conveyance of electricity from the Swartboois (Otjimuhaka) sub station. ➢ The construction of a separate accessory works / processing area for the rare-earth and iron- titanium ores in the southwestern sector of ML40. Impact Assessment The assessment of the identified potential impacts was undertaken after due consideration of all the physical, biological and socio-economic environment. The table below provides the expected outcomes of the assessment after mitigations are applied. The chapter on impact assessment more fully gives the reasons for these outcomes. The results have been incorporated into the environmental management plan and the programmes that will facilitate the implementation of the measures that are required. Here is the list of the aspects assessed. The biodiversity and water impact assessment outcomes are discussed in more detail hereafter. ➢ Air quality ➢ Noise ➢ Health & safety ➢ Visual ➢ Land use ➢ Waste ➢ Ecological & Biodiversity ➢ Water Resource ➢ Socio-economic ➢ Traffic ➢ Product Handling & Port Storage ➢ Heritage ➢ Post Mining Legacy

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Mitigation Status Mitigation Severity Duration Scale Spatial Consequence Probability of Occurrence Significance

Air Quality Impacts Disturbances to soil, rock and ore resulting in excessive dust in the atmosphere Mitigated L L M L L L Noise Impacts Disturbance of sense of place and the effect on tranquil ambient noise levels Mitigated L M M L L L Health & Safety The effects of excessive noise and vibration on the health and safety of Impacts – Noise and personnel. Vibration Effects on Personnel Mitigated L M L L L L Health & Safety Injury risks due to normal working conditions Impacts – General Hazards and Potential Risk of Injury Mitigated L L L L L L Health Impact Disease or normal health risk due to normal working conditions and in particular to exposure to radioactive particulates Mitigated L L L L L L Visual Impact Changes to the aesthetic appeal of the area due to presence of people, vehicles and machinery. Visible changes to habitats due to human activities. Mitigated L M L L M M Land Use Impact Herders could potentially experience restrictions to their grazing areas Mitigated L M L L L L Waste Impact Waste is generated during the construction, operational and decommissioning phases of the mine’s life. Waste can be classified into mineralised and non-mineralised waste. Non-mineralised waste can be classified as non-hazardous and hazardous waste. Medical waste is an additional category. Mitigated L M L L L L Socio-economic Positive aspect of sustaining employment in the sector Impact Mitigated M+ M+ M+ M+ H+ M+

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Mitigation Status Mitigation Severity Duration Scale Spatial Consequence Probability of Occurrence Significance

Traffic Impact Transporting bulk by trucks (PBS) along national roads Mitigated M M H M L M Product Handling & Bulk storage and handling of product at Walvis Bay Port Port Storage Impact Mitigated L L L L L L Heritage Impact Heritage related impacts Mitigated L H L M L L Post Mining Legacy Abandonment of the mining site potentially exposes public and wildlife to Impact hazards Mitigated L M L L L L The outcomes of the specialist studies are summarised here. Biodiversity studies Three habitat types were identified in the vegetation and vertebrate studies for this project and were integrated in one combined floral and faunal classification: a) mopane scrub, b) rocky outcrops, and c) river/drainages. The habitats were rated as to their sensitivity, with the caveat that all habitats are sensitive to disturbance and deserving of conservation measures. A sensitivity rating was assigned based on properties of the habitat itself, including: − nationally or regionally scarce habitats − size of habitat, in the context of the total availability of comparable habitats in Namibia and/or the region. − exceptionally high diversity and/or abundance of species − high level of endemism − support to species of conservation concern − key ecological processes − contribution to ecological functions (nutrient and energy flows) − provision of critical resources − restorability after disturbance Human habitation, grazing and mining activities have resulted in modified areas, to the extent that some of them are rendered severely degraded such as the rocky ridge south of ML40 and the quarry/mine sites. The village Oroutumba, located in Mopane scrub habitat adjacent to the Ondoto River, also constitutes an anthropologically modified area. The assessment considered all project activities and how these could potentially impact the various habitats.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Flora The largest part of ML40 consists of open mopane scrubland. The topography is gently undulating, bisected by drainage lines and ridges topped with rocky outcrops. The vegetation structure varies slightly from west to east, broadly corresponding to changes in topography with larger Mopane trees and some Commiphora species in the western parts of the study area. In the east and southeast Colophospermum mopane form a scrubby open woodland of homogenous height and structure, interspersed with Catophractes alexandri. The substrate consists of loose stones and gravel on compacted sand. The understorey is sparse, and grass was the only ground cover observable at the end of winter, but more annual plant species are expected to appear after rain. The accessory works areas will be established within this habitat. The rocky outcrops generally occur at the top of ridges in ML40 and the other mineral licences, and closely follows fenitisation in the area. The vegetation structure is layered, providing resources for a variety of animal taxa. A ground cover of grass was observed and although no forbs were present at the time of the site visit, they will appear in summer and after rain. There is a sub storey of shrubs and a well-developed upper storey of trees. This habitat has both abundance and richness of plants that are much higher than those of the surrounding scrubland, thereby contributing to its ecological value. The location of the study area in the foothills of the Zebra Mountains and in the Kaokoveld centre of endemism, a biogeographical region rich in range-restricted plants and animals, further increases the sensitivity of the habitat. Sodalite and the rare earth minerals are located here; it is where mining will be done and where most of the irreversible impacts (drilling, blasting and open cast mining) will take place. Lastly the riverine habitat. Although it crosses the study area for less than a kilometre, it is an important habitat in terms of both the study area and the region because of two reasons. Firstly, the drainages within ML40 flow into the river and from here it is only six kilometres from where it flows into the Kunene River. Secondly, it is an important source area of high diversity in an arid landscape and a resource during drought years. Any activity in the catchment (i.e. within ML40) could potentially affect the ecology of the Ondoto and Kunene rivers negatively. This stretch of the river situated within ML40 and its banks contain sparsely distributed large trees, few shrubs and ground cover in the form of annual plants such as grasses and forbs are expected to appear in summer and after rain. The substrate is sandy, with scattered rocks and boulders and a shallow stream. The river is an important resource for the Oroutumba community, and it has been modified by historic and current human activities such as grazing and harvesting. Cattle and goats were observed in the river, as well as daily human household activities (water collection, laundry and playing children). Four potential impacts were identified, two of which have a medium significance that becomes low after mitigation. Destruction of organisms and habitats and alteration of topography both have high unmitigated significance but potentially decrease to medium significance through the application of management measures if these are carried out effectively.

Mitigation Status Mitigation Severity Duration Scale Spatial Consequence Probability of Occurrence Significance

Impact Habitat and plant destruction

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Mitigated M M L M M M Impact Alteration of topography Mitigated M M L M M M Impact Groundwater drawdown Mitigated L M M L L L Impact Contamination of soil and water Mitigated L L L L L L The following recommended mitigation measures have been incorporated into the Draft EMP: ➢ Keep the overall development footprint as small as possible. ➢ The extent and location of any construction site should be clearly marked out and signage used to restrict movement of vehicles and personnel outside this area. ➢ Roads, pipelines and power lines must be planned in order to minimise fragmentation or disturbance of the habitats. ➢ Anti-erosion measures must be taken where roads and tracks cross a wash or drainage line. ➢ Carefully plan the placement of stockpiling construction material, i.e. lay-down areas to avoid sensitive areas. ➢ Limit construction activities to daytime hours to reduce noise. ➢ Educate construction and permanent staff as to their environmental obligations. All contractors should be held responsible for transgressions and significant penalties should be enforced in order to ensure compliance. ➢ Position temporary construction infrastructure (e.g. accommodation) in areas that will be disturbed during operations in any case. ➢ Erect linear structures (power lines, water pipelines) as close as possible to existing roads and tracks. ➢ Do not put water tanks, power pylons or any other large infrastructure in the river or washes. ➢ No sewerage overflow or French drain may be placed within 100 m of a drainage line. ➢ No illegal collection of plants should be allowed. ➢ No illegal collection of wood for fires (cooking or heating) should be allowed. ➢ A comprehensive restoration plan should be finalised during the first three years of initial clearance period. The Draft EMP includes a conceptual framework for habitat restoration or rehabilitation. Provision for monitoring and adaptive management as the project develops is imperative. Some rehabilitation actions should be implemented during operations in order to be effective, e.g. removal and location of topsoil; location of waste rock dumps to ensure efficient restoration later. ➢ Monitor groundwater levels to ensure sustained growth of trees. ➢ Monitor plant diversity downriver from the abstraction site at a minimum once a year. ➢ Abstract water from a site where infiltrate from the Kunene River is available. ➢ TSF containment measures should be strictly enforced to the highest existing standards. ➢ Regularly inspect structures related to the Tailings Storage Facility. ➢ Treatment of the final discharge of water should be in such a way as to eliminate any possibility of active chemicals entering the soil or groundwater. No impact on the vegetation is permissible, especially downstream along the drainage lines. Four impacts were identified, two of which have a medium significance that becomes low after mitigation. Impact 1 (destruction of organisms and habitats) and impact 2 (alteration of topography) both have high unmitigated significance, decreased to medium significance by the stringent application of management measures.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

The cumulative nature of mining activities in the Kunene Region and in the Kaokoveld Centre of Endemism, the irreversible damage to the rocky ridges (sensitive, ecologically valuable habitat) and the persistence of excavations after the lifespan of the mine are three factors that lower the likelihood of impacts 1 and 2 being mitigated to the low significance rating. However, the strict implementation of mitigation measures and a professional restoration plan can improve the situation significantly for some habitats and aspects such as the accessory works, linear infrastructure, tailings facilities and waste rock dumps. It is important to keep the overall project footprint to the absolute smallest size possible, and to keep it inside well-defined and clearly demarcated boundaries by putting up visible and effective signs, and fencing the operational area where possible, such as the accessory works and tailings facilities. The purpose of a fence and signs is to inform personnel and contractors of the exact boundaries of the operations area and to effectively control access to areas that will remain undeveloped. Fences and signage go hand in hand with appropriate environmental training and awareness raising of staff, and of contractors and their staff. A key habitat is the rocky outcrops that support many species that would otherwise not be present. As mineral-bearing ore is located almost exclusively on the ridges and rocky outcrops, restoration of this habitat after mining operations will not be possible. To mitigate the loss of these outcrops, a botanical expedition is recommended to identify the most important sites and sacrifice the other less sensitive areas and to confirm the degree to which habitat destruction would affect the overall plant diversity of the greater area. The Ondoto River is considered very sensitive and apart from the proposed borehole and water pipeline, no development should take place there. During operations the riverbed should be designated a no-go area, except for essential maintenance to the borehole and pipeline. The natural flow patterns in washes and drainages should be maintained, particularly important when designing and constructing a road network, power line, water pipeline and any other linear development. Waste rock dumps and tailings facilities should be placed where least impact on diversity would occur, preferably in the mopane scrub towards the east if possible) For a restoration programme to be effective, it is essential that it be implemented from the earliest possible time after the construction phase, and throughout the operational phase where possible. The protection of source areas from where seeds and organisms will originate to re-colonise the disturbed areas is a crucial aspect of restoration, and source areas need to be identified and protected from the planning phase, throughout operations and during decommissioning and closure. Accurate financial projections need to be made, and financial mechanisms for implementing restoration measures should be put in place before operations. The restoration plan should be developed by an expert in conjunction with the mine planners and engineers, and it should be fully integrated with the mine’s EMP during the first three years of the environmental clearance period. In the light of the irreversible damage that will be done to the sensitive rocky outcrops and the cumulative nature of the impacts of mining in the Kunene Region, it is proposed that the NBRI conduct a full-scale botanical survey. Such an investigation is considered an essential part of mitigation and will inform the restoration planning and EMP amendments during the first three years of the clearance period. The aims of the expedition will be: ➢ Record and assess the taxa that are likely to be affected by the development. ➢ Collect seeds and/or cuttings of vulnerable species and transplant valuable specimens if feasible. ➢ Make recommendations for the restoration plan and EMP in cooperation with other specialists and the mine planners. It is recommended that the survey of ML40, in particular the rocky outcrops concerned with the planned mining operation, be conducted after the summer rains and that it be done in cooperation with the NBRI. Because of its remoteness, the region is botanically under-surveyed and under-collected

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021 and the participation of the NBRI will not only ensure a comprehensive baseline understanding of the existing environment, but also provide a community service by making the data available to the public. Fauna A key habitat in the larger woodland mosaic is the rocky outcrops habitat. The physical diversity of the hills and rocky ridges leads to a higher and more specialised biodiversity than the surrounding Mopane woodland, and it supports many species that would otherwise not be present. Seeing as mineral- bearing ore is located almost exclusively in the rocky ridges, restoration of this habitat after mining operations will not be possible to any meaningful extent. Riverine habitat has a high ecological value for all taxa, it plays a keystone role in nutrient transport, and serves as important source areas for recolonisation after operations cease. In this project footprint, the Ondoto River is considered very sensitive and apart from the proposed linear infrastructure, no development should take place there. In addition, the natural flow patterns in washes and drainages should be maintained, particularly important when designing and constructing a road network and any other linear development. Destruction of organisms and habitats and alteration of topography both have high unmitigated significance, but potentially decrease to medium significance through the application of management measures if those are carried out effectively. As mentioned above the cumulative nature of mining activities in the Kunene Region and in the Kaokoveld Centre of Endemism, the irreversible damage to the rocky outcrops (as the most sensitive, ecologically valuable habitat) and the persistence of the excavations after the lifespan of the mine, are three factors that lower the likelihood that these impacts can be mitigated to a low significance rating. Again, the strict implementation of mitigation measures and restoration plan can improve the situation significantly for other habitats and aspects such as the accessory works, linear infrastructure and any staff accommodation areas. Seven impacts were identified. Five of these impacts are rated as having medium significance, mitigated to a low significance rating provided the suggested management measures are implemented.

Mitigation Status Mitigation Severity Duration Scale Spatial Consequence Probability of Occurrence Significance

Impact 1 Destruction of organisms and their habitats

Mitigated M M L M M M Impact 2 Disturbance of animals and interference with their behaviour Mitigated L L L L L L Impact 3 Light Pollutions Mitigated L M L L M L Impact 4 Alteration of topography Mitigated M M L M M M

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Impact 5 Groundwater drawdown Mitigated L M M L L L Impact 6 Contamination of soil and water Mitigated L L L L L L Impact 7 Impacts associated with the accommodation of staff Mitigated L L L L L L The following recommended mitigation measures have been incorporated into the Draft EMP to minimise the potential impacts on fauna expected from the project: ➢ Keep the overall development footprint as small as possible. ➢ The extent and location of the construction site and operational areas should be clearly marked out and signage used to restrict movement of vehicles and personnel outside this area. ➢ Fencing is recommended for the processing plant and TSF where both fauna and public could be at risk. ➢ The location of roads, pipelines and power lines must be planned in order to minimise fragmentation or disturbance of habitats. ➢ Anti-erosion measures must be taken where roads and tracks cross a wash or drainage. ➢ Carefully plan the placement of stockpiling construction material, i.e. lay-down areas to avoid sensitive ground. ➢ Limit construction activities to daytime hours to reduce noise. ➢ Educate construction and permanent staff as to their environmental obligations. All contractors should be held responsible for transgressions and significant penalties should be levied in order to ensure compliance. ➢ Position temporary construction infrastructure (e.g. accommodation) in areas that will be disturbed during operations in any case. ➢ Areas surrounding the mine, processing plant and exploration sites that are not part of the demarcated development should be considered no-go zones for employees, visitors, vehicles or machinery. ➢ No off-road driving or driving next to established roads/tracks should be allowed. ➢ Limit activities to day-time hours to reduce noise. ➢ No fires outside a controlled area (eg. drum, braai area etc) should be allowed so that the natural vegetation does not burn in an uncontrolled way. ➢ Staff and contractors should be trained in sensitive human-wildlife interactions. ➢ Erect linear structures (power lines, water pipelines) as close as possible to existing roads and tracks. Maintenance roads/tracks for linear structures should be built as close as possible to these structures and access should be limited to essential maintenance. ➢ Do not put water tanks, power pylons or any other large infrastructure within or in the vicinity of drainage lines. ➢ No sewerage overflow or French drain may be placed within 100 m of drainage lines. ➢ A vertebrate specialist is recommended for identifying nests, dens and other breeding locations and demarcate them before construction so that these sites can be avoided as part of the EMP. ➢ Reptiles and amphibians that are exposed during ground clearing should be captured for translocation by a qualified expert. ➢ A comprehensive restoration plan should be finalised during the first three years of initial clearance period. The Draft EMP includes a conceptual framework for habitat restoration or rehabilitation. Provision for monitoring and adaptive management as the project develops is imperative. Some rehabilitation actions should be implemented during operations in order to

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

be effective, e.g. removal and location of topsoil; location of waste rock dumps to ensure efficient restoration later. ➢ Not much is known about the effect of artificial light on populations and ecosystems and the precautionary principle is applied here. ➢ Install motion detectors to limit light use to the minimum possible. ➢ Outdoor lights should be directed downwards and not up into the sky. ➢ Use yellow or amber outdoor lights because invertebrates don't detect yellow light as well as white. ➢ Install insect screens in doors and windows located in buildings that are used after sunset. ➢ Landscaping of waste rock dumps can become new rocky habitats for recolonisation of flora and fauna, and they should be made according to the provisions of the restoration plan and EMP. ➢ Monitor groundwater levels. ➢ Monitor plant and vertebrate diversity downriver from the abstraction site at a minimum of once a year. ➢ Using an alternative source of water like the Kunene River is expected to mitigate the impact on groundwater levels. ➢ Animals should not be able to enter the TSF area. ➢ Regularly inspect structures related to the Tailings Storage Facility. ➢ Containment of the discharge of TSF water will eliminate any possibility of dangerous chemicals entering the soil or groundwater. ➢ All inhabitants and visitors in the staff compound should receive environmental awareness training, including training on indiscriminate defecation. ➢ The staff accommodation area should be fenced in and the only access allowed outside the fence is along the entrance road. ➢ All cleaning and washing should take place inside a designated area (e.g. kitchen, laundry) and fat traps should be installed at the drain outlet from these areas. ➢ Gas cooking facilities should be provided instead of allowing wood or charcoal fires for cooking. ➢ Firefighting equipment should be placed in the compound. It should always be tested regularly and in working condition. All inhabitants of the compound should be trained in the use of this equipment and know where it is. ➢ Water saving measures should be put in place, e.g. low-pressure shower heads and taps; daily checks of pipes and tanks; immediate repair of leaks. ➢ Sewerage should be of sufficient capacity for the expected number of people. Impact 1 (destruction of organisms and habitats) and impact 4 (alteration of topography) both have high unmitigated significance, decreased to medium significance by the stringent application of management measures. These impacts can be mitigated to a medium significance rating providedstrict implementation of mitigation measures and the restoration plan occurs. It is important to keep the overall project footprint to the absolute smallest size possible, and to keep it inside well-defined and clearly demarcated boundaries by fencing the operational area and putting up visible and effective signs. The purpose of a fence or at the least signs will inform personnel and contractors of the exact boundaries of the operations area and to effectively control access to areas that will remain undeveloped. Fences and signage go hand in hand with appropriate environmental training and awareness raising of staff, and of contractors and their staff. A key habitat in the larger woodland mosaic is the rocky outcrops habitat. The physical diversity of the hills and rocky outcrops leads to a higher and more specialised biodiversity than the surrounding Mopane woodland, and it supports many species that would otherwise not be present. Seeing as mineral-bearing ore is located almost exclusively in the rocky outcrops, restoration of this habitat after mining operations will not be possible to any meaningful extent.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Riverine habitat has a high ecological value for all taxa, plays a keystone role in nutrient transport, and serves as important source areas for recolonisation after operations cease. In this project footprint, the Ondoto River is considered very sensitive and apart from the proposed linear infrastructure, no development should take place there. In addition, the natural flow patterns in washes and drainages should be maintained, particularly important when designing and constructing a road network and any other linear development. For a restoration programme to be effective, it is essential that it be implemented from the earliest possible time after the construction phase, and throughout the operational phase where possible. The protection of source areas from where seeds and organisms will come to re-colonise the disturbed areas is a crucial aspect of restoration, and source areas need to be identified and protected from the beginning. Some mitigation measures need to be implemented during operations to be effective; potential examples include the removal and storage of topsoil, placement of roads, and the shape and placement of waste rock stockpiles. Accurate financial projections need to be made, and financial mechanisms for implementing restoration measures should be put in place before operations. These are some of the reasons why restoration, at least at conceptual level, should be part of the planning phase. Because the project design has not been finalised, it is not possible to draft a complete restoration programme at this early stage. It is, however, possible to develop a conceptual plan that defines the most likely first implementation steps, as well as the structure of an adaptive management and monitoring plan. The restoration plan should be developed by an expert in conjunction with the mine planners and engineers, and it should be fully integrated with the mine’s EMP. Water Study The hydrology and hydrogeology study provides valuable input into the project for water supply and flood water management where contamination is a risk. Details on rock and soil chemistry will be supplied in a second phase of the water study which is necessary in the design of the TSF for the new processing plant. The mining area is topographically elevated and slopes northward towards the Kunene River. A large ephemeral river, the Ondoto, flows north to the Kunene through the project area and the mining area is in the Ondoto River catchment. The current assessment primarily focusses on possible environmental impact from the planned REE mining activities on the Ondoto River and the alluvial aquifer, in terms of water quality and as a sustainable water source. Groundwater potential of the Ondoto alluvial aquifer is moderate and as the local community is dependent on this source for water, use of alternative water sources is recommended for the envisaged long-term mining and processing operations. Alternative water sources were identified, such as, direct intake from the Kunene River and development of the Dwyka Group sandstone aquifer along the banks of the Kunene River. The assessment has identified the management of the tailings and waste rock from processing of REE ore as important environmental concerns as the ore processing activities are located upstream of the Ondoto and Kunene Rivers. Based on the hydrological study, measures for stormwater management and containing any effluent from the processing facility and waste are proposed. The potential for contamination through mobilisation of contaminants from the tailing and waste is considered low due predominance of carbonate minerals in the ore and resulting alkaline conditions of the waste rock and tailings. Possible contaminants such as thorium are being removed from site in the REE concentrate product. The impact of sodalite mining to a maximum depth of 40 meter is limited as the groundwater level is deep, usually exceeding 100 m below ground level. However, recent exploration showed that groundwater may be situated from 30 m below ground level. Management of groundwater seepage and stormwater in the quarries and around the accessory work areas is recommended.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

The following table provides the mitigated assessment significance for the water resource aspects.

Mitigation StatuMitigation Severity Duration Scale Spatial Consequence Probability of Occurrence Significance

Impact Mining activities may affect water resources through over utilisation Mitigated M M L M L L Impact Mining activities may affect water resources through contamination Mitigated M L L M L L Water use sustainability will be achieved if the following mitigations are employed: ➢ Limit the use of the Ondoto River alluvium to initial stages of the project only. ➢ If the Ondoto River alluvial aquifer shows signs of overexploitation (drop in groundwater level and increasing salinity) and is not replenished within a year of use by the mine, then use of the resource should be stopped, and the alternative sources used. The community affected by the disruption of supply should be supplied from the alternative source till supply from the Ondoto River is restored. ➢ Develop the alternative source of water (Kunene river or Dwyka aquifer) for sustainable long- term use. Water Study Mitigation Measures for the soils, surface water and groundwater are as follows: ➢ Construction of a containment dam downstream of the processing plant, TSF, waste rock dump and other stockpiles. Thereby capture all water that is potentially contaminated. ➢ Evaporation of contained water that is not reused. ➢ Maintain water balance as a check on any significant water leakage from the operation. ➢ Regular inspection of TSF and WRDs. ➢ During the operation of the mine, the sediment material accumulated in the containment dam should be moved to the tailings at regular intervals so that the maximum capacity of the containment dam is retained and the risk of mobilising the material downstream is reduced. For the management and mitigation of possible impacts from the mining pits the following measures are recommended: ➢ The pits to a maximum depth of 40 m bgl may below the groundwater level and groundwater inflow could expected when mining to this depth. ➢ Surface flow to the pits is also possible and the pits should be protected against inflow of surface runoff water and discharge from the pits should be avoided. Therefore, the pits should be cordoned off with berms (1 m high) to avoid surface inflow to the pit Management Plan

All the mitigation measures listed by the specialists have been considered for inclusion in the Draft Environmental Management Plan (EMP). Where a mitigation measure was deemed unrealistic and not necessary, justification for such decision is given. The Draft EMP also provides for the monitoring requirements as well as for the required rehabilitation activities.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Fluctuations in market demand may affect the mine from time to time. Should the mining project have to be closed permanently then rehabilitation of the mining area would need to be undertaken. A mine closure plan should take into consideration the recommended rehabilitation measures highlighted in the EMP. Some restoration or rehabilitation work should take place at the end of construction phase where activities resulted in disturbances along the pipeline routes, new roads development along linear infrastructure routes.

For a restoration programme to be effective, it is essential that it be implemented from the earliest possible time after the construction phase, and throughout the operational phase where possible. The protection of source areas from where seeds and organisms will come to re-colonise the disturbed areas is a crucial aspect of restoration, and source areas need to be identified and protected from the onset. Some mitigation measures need to be implemented during operations to be effective; potential examples include the removal and storage of topsoil, planning and placement of roads, and the shape and placement of waste rock stockpiles. Accurate financial projections need to be made, and financial mechanisms for implementing restoration measures should be put in place before operations. These are some of the reasons why restoration, at least at conceptual level, should be part of the planning phase.

Concluding Remarks

The EAP deems the project to be acceptable considering the input of the specialists and the majority low significance of the potential impacts provided the necessary mitigation measures and ongoing rehabilitation measures are all implemented with monitoring. It is the author’s opinion that the environmental clearance be granted on condition that the Draft Environmental Management Plan be effectively implemented.

1 CONTENTS EXECUTIVE SUMMARY ...... 1 1 BACKGROUND AND INTRODUCTION ...... 31

1.1 MINE LEGACY ...... 32

1.2 EXPLORATION ...... 32 2 EIA TERMS OF REFERENCE ...... 33

2.1 SCREENING, PLANNING, SITE VISITS & SCOPING ...... 33

2.2 LEGAL FRAMEWORK ...... 33

2.3 PROJECT DESCRIPTION ...... 33

2.4 PUBLIC PARTICIPATION PROCESS ...... 33

2.5 ENVIRONMENT DESCRIPTION ...... 34

2.6 IMPACT ASSESSMENT ...... 34

2.7 ENVIRONMENTAL MANAGEMENT PLANNING (EMP) ...... 34 3 ADMINISTRATIVE, LEGAL AND POLICY REQUIREMENTS ...... 35 4 PROJECT DESCRIPTION ...... 45

4.1 PROJECT RATIONALE / NEED AND DESIRABILITY ...... 45

4.2 NATURE & SIZE OF THE PROJECT ...... 45

4.3 LOCATION DETAILS ...... 46

4.4 ACCESSIBILITY ...... 47

4.5 PROPOSED PROJECT PLAN ...... 48 4.5.1 Construction Phase Activities ...... 48 4.5.2 Operational Phase Activities ...... 55 4.5.3 Decommissioning Phase ...... 60 4.5.4 No Go Project Option ...... 61 5 PUBLIC CONSULTATION ...... 61

5.1 SITE NOTICES ...... 64

5.2 PRESS NOTICES ...... 64

5.3 BACKGROUND INFORMATION DOCUMENT ...... 64

5.4 PUBLIC MEETINGS & FOCUS GROUP MEETINGS ...... 64

5.5 STAKEHOLDER NOTIFICATION ...... 64

5.6 PUBLIC CONSULTATION OUTCOMES ...... 65

5.7 PUBLIC REVIEW & REPORT FINDINGS FEEDBACK ...... 66 6 DESCRIPTION OF THE ENVIRONMENT...... 67 6.1 GEOLOGY ...... 67 6.1.1 Regional Geology ...... 67 6.1.2 Local Geology ...... 67 6.2 SOILS ...... 68

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

6.3 HYDROLOGY ...... 68 6.3.1 Ondoto River System ...... 69 6.3.2 Kunene River ...... 70 6.3.3 Storm Water Management Plan: Canals, Diversions & Contamination Containment ...... 72 6.4 GROUNDWATER ...... 75 6.4.1 Ondoto River alluvium...... 76 6.4.2 Quality of groundwater in the project area and surroundings ...... 77 6.4.3 Anorthosite of the Kunene Complex ...... 78 6.4.4 Dwyka Group sediments ...... 79 6.4.5 Supply Infrastructure ...... 81 6.4.6 Discussion on water supply options ...... 81 6.5 CLIMATE ...... 82 6.5.1 Temperature ...... 82 6.5.2 Wind ...... 83 6.5.3 Rainfall ...... 84

6.6 BIOLOGICAL ENVIRONMENT ...... 85 6.6.1 Habitat Classification (Potgieter, 2020a) ...... 85 6.6.2 Flora (Potgieter, 2020a) ...... 88 6.6.3 Fauna ...... 90

6.7 SOCIO-CULTURAL ENVIRONMENT ...... 96 6.7.1 Introduction ...... 96 6.7.2 Demography ...... 96 6.7.3 Regional Economics ...... 96 6.7.4 Education ...... 96 6.7.5 Land Use ...... 96 6.7.6 Residence Survey ...... 97 6.7.7 Infrastructure and Services...... 100 6.7.8 Cultural Heritage ...... 100 6.7.9 Potential Impacts ...... 100 7 IMPACT ASSESSMENT ...... 103 8 ENVIRONMENTAL MANAGEMENT PLAN ...... 137 9 CONCLUSIONS & RECOMMENDATIONS ...... 139 10 REFERENCES ...... 140 11 APPENDIX A: CURRICULUM VITAE OF ENVIRONMENTAL ASSESSMENT PRACTITIONER ...... 141 12 APPENDIX B: SITE NOTICES ...... 143 13 APPENDIX C: PRESS NOTICES (NEWSPAPER AVERTISEMENTS) ...... 147 14 APPENDIX D: BACKGROUND INFORMATION DOCUMENT ...... 149 15 APPENDIX E: PUBLIC PARTICIPATION REPORT ...... 166

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

MAIN POINTS RAISED DURING OTJIMUHAKA COMMUNITY MEETING AND OPUWO MEETING WITH GOVERNMENT OFFICIALS ...... 177 16 APPENDIX F: PRESENTATION DELIVERED AT MEETINGS ...... 181 17 APPENDIX G: MINUTES OF PUBLIC MEETINGS ...... 189 18 APPENDIX H: REGISTER OF STAKEHOLDERS & I&APS ...... 204 19 APPENDIX I: FLORA STUDY ...... 211 20 APPENDIX J: FAUNA STUDY ...... 212 21 APPENDIX K: WATER STUDIES...... 213 22 APPENDIX L: BRIDGE ASSESSMENT STUDY ...... 214 23 APPENDIX M: DRAFT ENVIRONMENTAL MANAGEMENT PLAN ...... 215 24 APPENDIX N: HERITAGE SURVEY REPORT ...... 216

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021 LIST OF FIGURES

FIGURE 1. LICENCE LOCATION RELATIVE TO THE REGION’S MAIN TOWNS ...... 31

FIGURE 2. THE LOCATION OF THE PROJECT’S MINING LICENCE (ML40) AND ASSOCIATED LICENCES SHOWING THE NEAREST PERMANENT COMMUNITIES...... 32

FIGURE 3. LOCATION OF ML40 SHOWING CORNER COORDINATES...... 46

FIGURE 4. IMAGES DEPICTING THE MAIN EXISTING SODALITE QUARRY (GROUND AND AERIAL IMAGE) ...... 46

FIGURE 5. THE LOCATION OF THE MINING LICENCE (ML) 40 RELATIVE TO OPUWO...... 47

FIGURE 6. MAP RENDERING THE APPROXIMATE ROUTES OF THE LINEAR INFRASTRUCTURE...... 48

FIGURE 7. NEW PROCESSING PLANT AREA SHOWING WATER PIPELINE EXTENSION FROM OROUTUMBA SETTLEMENT...... 49

FIGURE 8. PROPOSED LOCATIONS OF SURFACE RUNOFF DIVERSION AND CONTAINMENT DAM, PROCESSING AND TSF AND WRD AREAS (SARMA, 2021) ...... 50

FIGURE 9. ORIGINAL ACCESSORY WORKS APPLICATION SHOWING PROCESSING PLANT DETAILS...... 54

FIGURE 10. IMAGES OF SODALITE QUARRY MACHINERY (BLOCK CUTTER ON LEFT AND EXCAVATOR ON RIGHT) ..... 55

FIGURE 11. LOCATION OF THE NEW PROCESSING PLANT, ACCESSORY WORKS AREA WITH TSF, WRD, WATER RESERVOIR AND ORE STOCKPILE AREA IN ADJACENT THE MINING CLAIM...... 56

FIGURE 12. THE PREFERRED HAULAGE ROUTE FOR TRANSPORTING THE VARIOUS PRODUCTS TO THE WALVIS BAY PORT...... 58

FIGURE 13. LAYOUT OF WALVIS BAY PORT AND LOCATIONS OF BULK STORAGE OPTIONS (BULK PLOT NO. 10, 17, 20, 37) ...... 59

FIGURE 14. A MAP OF THE VARIOUS TYPES OF CARBONATITE DYKES DISCOVERED IN AND AROUND THE ML40 AREA. 68

FIGURE 15. ONDOTO SUB CATCHMENTS...... 69

FIGURE 16. KUNENE RIVER ANNUAL RUNOFF AT RUACANA ...... 70

FIGURE 17. KUNENE RIVER HYDROGRAPH, RUACANA...... 71

FIGURE 18. DAILY MEAN DISCHARGE - KUNENE RIVER AT RUACANA...... 71

FIGURE 19. ML40 CATCHMENTS ...... 73

FIGURE 20 POTENTIAL EXCAVATIONS, PROCESSING, AND TAILINGS AREA IN ML40 ...... 75

FIGURE 21. AREA OF ADDITIONAL CONCERN – ZONE 1 ...... 75

FIGURE 22. HAND-DUG WELL IN THE ONDOTO RIVER ALLUVIUM USED TO SUPPLY THE MINING CAMP AND LOCAL COMMUNITY...... 77

FIGURE 23. ONDOTO RIVER ALLUVIAL DEPOSIT BETWEEN BEDROCK OUTCROPS CLOSE TO MINING LICENSE 40. ... 77

FIGURE 24. SCHEMATIC NORTH-SOUTH SECTION FROM THE KUNENE RIVER TO THE SOUTH SHOWING THE CONCEPTUALISED GROUNDWATER LEVEL IN THE BEDROCK ...... 79

FIGURE 25. ARENACEOUS UNIT WITHIN DWYKA GROUP SEDIMENTS IN THE SOUTHERN BANK OF THE KUNENE RIVER ...... 80

FIGURE 26. GEOLOGY OF THE PROJECT AREA (AFTER MILLER, 2008)...... 81

FIGURE 27. MAP SHOWING THE SOURCE OF THE WATER SUPPLY OPTIONS, PIPELINE ROUTES AND RESERVOIRS. ... 82

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

FIGURE 28. MODELLED AVERAGE, MINIMUM AND MAXIMUM TEMPERATURES FOR EACH MONTH OF THE YEAR FOR THE PERIOD 2016 TO 2018 FOR OPUWO (LIEBENBERG-ENSLIN 2019) ...... 83

FIGURE 29. MODELLED WIND DATA FOR THE SEASONS FROM 2016 TO 2001 FOR OPUWO (LIEBENBERG-ENSLIN 2019) ...... 84

FIGURE 30. OPUWO ANNUAL RAINFALL DATA FROM 1940 TO 1998 (LIEBENBERG-ENSLIN 2019)...... 85

FIGURE 31. IMAGES OF THE THREE HABITAT TYPES CATEGORISED FOR THE AREA ...... 90

FIGURE 32. MAP OF HABITATS IN THE STUDY AREA ...... 91

FIGURE 33. MAP SHOWING THE EXTENT OF THE KUNENE RIVER CONSERVANCY ...... 97

FIGURE 34. LOCATIONS OF THE POTENTIAL HOMESTEADS SURVEYED RELATIVE TO THE MINERAL LICENCES...... 99

FIGURE 35. DWELLINGS NEAR THE NEW PROCESSING PLANT ...... 99

FIGURE 36. SITE LOCATIONS OF THE HERITAGE SURVEY...... 101

LIST OF TABLES

TABLE 1. APPLICABLE EMA LISTED ACTIVITIES ...... 35

TABLE 2. ADDITIONAL NATIONAL AND INTERNATIONAL LEGISLATION...... 38

TABLE 3. DESIGN FLOOD CALCULATIONS – PROCESSING AND TSF AREA ...... 50

TABLE 4. CONTAINMENT DAM SIZING - PROCESSING AND TSF AREA ...... 51

TABLE 5. DAM SPILLWAY DESIGN – PROCESSING AND TSF AREA ...... 51

TABLE 6. PRELIMINARY PIPELINE SIZING ...... 52

TABLE 7. ESTIMATED PUMP STATION POWER REQUIREMENTS ...... 52

TABLE 8. PREFERRED AND ALTERNATIVE ROAD ROUTES FOR HAULAGE TRUCKS...... 57

TABLE 9. IMPORTANT DATES AND ACTIONS RELATED TO THE PUBLIC PARTICIPATION PROCESS ...... 61

TABLE 10. THE MAIN POINTS OF CONCERN RECEIVED FROM PEOPLE WHO ATTENDED THE PUBLIC MEETINGS...... 65

TABLE 11. DETAILS OF THE ONDOTO SUB-CATCHMENT (ABSTRACTED FORM TABLE 45 – UNIT RUNOFF MAP OF NAMIBIA) ...... 69

TABLE 12. ML40 CATCHMENT AREAS ...... 73

TABLE 13. SURFACE RUNOFF ENTERING ML40 ...... 73

TABLE 14. SURFACE RUNOFF GENERATED WITHIN ML40 ...... 73

TABLE 15. RESIDENCE SURVEY DATA (WAYPOINTS CORRESPOND WITH FIGURE 35 ABOVE) ...... 100

TABLE 16. CRITERIA FOR ASSESSING IMPACTS...... 104

TABLE 17. AIR QUALITY IMPACTS ...... 105

TABLE 18. NOISE IMPACTS ...... 106

TABLE 19. HEALTH & SAFETY IMPACTS – NOISE AND VIBRATION EFFECTS ON PERSONNEL ...... 107

TABLE 20. HEALTH & SAFETY IMPACTS – GENERAL HAZARDS AND POTENTIAL RISK OF INJURY...... 109

TABLE 21. HEALTH IMPACT DUE TO EXPOSURE TO RADIOACTIVE PARTICULATES AND NORMAL WORKING CONDITIONS...... 111

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

TABLE 22. VISUAL IMPACTS ...... 113

TABLE 23. LAND USE IMPACT ...... 116

TABLE 24. WASTE IMPACT ...... 117

TABLE 25. ECOLOGICAL & BIODIVERSITY IMPACTS ...... 119

TABLE 26. WATER RESOURCE IMPACT – OVER UTILISATION ...... 126

TABLE 27. WATER RESOURCE IMPACT – POTENTIAL CONTAMINATION ...... 128

TABLE 28. SOCIO-ECONOMIC IMPACT ...... 130

TABLE 29. TRAFFIC IMPACTS ...... 131

TABLE 30. PRODUCT HANDLING & STORAGE IMPACTS ...... 132

TABLE 31. HERITAGE IMPACTS ...... 134

TABLE 32. POST MINING LEGACY IMPACT ...... 135

TABLE 33. TIMETABLE OF PUBLIC CONSULTATIONS...... 171

TABLE 34. SUMMARY OF ISSUES RAISED IN THE PUBLIC CONSULTATION PROCESS...... 174

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021 LIST OF ABBREVIATIONS AMSL Above Mean Sea-Level BID Background Information Document bgl Below ground level CRO Chief Regional Officer DEA Directorate of Environmental Affairs DRWS Directorate of Rural Water Supply EA Environmental Assessment EAP Environmental Assessment Practitioner ECC Environmental Clearance Certificate EMA Environmental Management Act No 7 of 2007 EMP Environmental Management Plan EMS Environmental Management System GRN Government HDPE High-density polyethylene IAPs Interested and Affected Parties IUCN International Union for Conservation of Nature JP John Pallett KAC Kunene Anorthosite Complex KNL Proponent Company Name MAP Mean Annual Precipitation MAR Mean Annual Runoff MEFT Ministry of Environment, Forestry and Tourism ML Mining Licence MLR Ministry of Land & Resettlement MME Ministry of Mines & Energy MoHSS Ministry of Health & Social Services NGO Non-Government Organisation NNW North North West PBS Performance Base Standard PPP Public Participation Process REE Rare Earth Elements SR Scoping Report TSF Tailings Storage Facility UNCCD United Nations Convention to Combat Desertification UNFCCC United Nations Framework Convention on Climate Change WNW West North West WRD Waste Rock Dump

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021 GLOSSARY OF TERMS Competent Authority A body or person empowered under the local authorities act or Environmental Management Act to enforce the rule of law. Environment As defined in the Environmental Assessment Policy and Environmental Management Act - “land, water and air; all organic and inorganic matter and living organisms as well as biological diversity; the interacting natural systems that include components referred to in sub-paragraphs, the human environment insofar as it represents archaeological, aesthetic, cultural, historic, economic, palaeontological or social values”. Environmental Process of assessment of the effects of a development on the environment. Assessment (EA) Environmental A working document on environmental and socio-economic mitigation Management Plan measures, which must be implemented by several responsible parties during all (EMP) the phases of the proposed project. Fenetization A quartzo-feldspathic rock that has been altered by alkali metasomatism at the contact of a carbonatite intrusive complex. Interested and Any person, group of persons or organisation interested in, or affected by an Affected Party (IAP) activity; and any organ of state that may have jurisdiction over any aspect of the activity. Kaokoveld Centre of A term used to describe the special endemic nature of the Kaokoveld area. Endemism Mitigate The implementation of practical measures to reduce adverse impacts. Proponent Any person who has submitted or intends to submit an application for an (Applicant) authorisation, as legislated by the Environmental Management Act no. 7 of 2007, to undertake an activity or activities identified as a listed activity or listed activities; or in any other notice published by the Minister or Ministry of Environment & Tourism. Scoping Process Process of identifying: issues that will be relevant for consideration of the application; the potential environmental impacts of the proposed activity; and alternatives to the proposed activity that are feasible and reasonable. Stakeholder The process of engagement between stakeholders (the proponent, authorities Engagement and IAPs) during the planning, assessment, implementation and/or management of proposals or activities. The level of stakeholder engagement varies depending on the nature of the proposal or activity as well as the level of commitment by stakeholders to the process. Stakeholder engagement can therefore be described by a spectrum or continuum of increasing levels of engagement in the decision-making process. The term is considered to be more appropriate than the term “public participation”. Stakeholders A sub-group of the public whose interests may be positively or negatively affected by a proposal or activity and/or who are concerned with a proposal or activity and its consequences. The term therefore includes the proponent, authorities (both the lead authority and other authorities) and all interested and affected parties (I&APs). The principle that environmental consultants and stakeholder engagement practitioners should be independent and unbiased excludes these groups from being considered stakeholders.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

1 BACKGROUND AND INTRODUCTION KNL of Namibia (Pty) Ltd (hereafter referred to as KNL or the Proponent) is a wholly owned Namibian company, which holds the mineral rights as granted with ML40, issued by the Ministry of Mines and Energy on 24 April 1997. KNL plans to continue mining sodalite dimension stone and start mining and processing of other minerals within Mining Licence 40 (ML40), which is located at the northern border of Namibia, near Otjimuhaka (previously Swartbooisdrif) in the Kunene Region. From 1997 to 2006 the company developed dimension stone quarries within ML40 together with the related mining and processing infrastructure at the accessory works area of the ML. Since 2017 no blocks of dimension stone have been extracted. Plans to expand the mining to iron-titanium ore and rare earth mineralisation have been drawn up. The accessory works area will be expanded to accommodate the processing of these additional ores. Figure 1 renders a map of the region’s main towns relative to the mining licence. Figure 2 renders the location of the project’s mining licence (ML40) and associated project licences showing the nearest permanent communities.

Figure 1. Licence location relative to the region’s main towns

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Figure 2. The location of the project’s mining licence (ML40) and associated licences showing the nearest permanent communities.

1.1 MINE LEGACY The ML40 ground and surrounding areas has undergone mining operations during the last 60 years. Small scale mining of lumps of sodalite and other ornamental stones is presently ongoing within ML40 and in a larger area of approximately 7 by 8 kilometres in extent. The Mining Claims are a recent acquisition though mining has occurred on some of these too.

1.2 EXPLORATION KNL undertook exploration drilling and resource modelling of the rock resource contained within its ML40 and large-scale block production took place within this Mining Licence during the period 1998 to 2006. Dimension stone operations discontinued in December 2017 and the mine is currently kept on small-scale lump production and processing. Exploration for other mineralisation within ML40 and the area of the 6 mining claims resulted in the planned expansion of the project to include mining of Iron-Titanium ore and Rare Earth Metals.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

2 EIA TERMS OF REFERENCE KNL appointed Philip Hooks, an independent Environmental Assessment Practitioner (EAP), to undertake the assessment and compile this scoping assessment report and Environmental Management Plan (EMP) in support of the application. The curriculum vita of the EAP is provided in Appendix A. The Terms of Reference for the proposed project is based on the requirements set out by the Environmental Management Act (EMA) (2007) and its EA Regulations (2012). The process covered the following steps, as divided into the sections below. Each section describes what was undertaken.

2.1 SCREENING, PLANNING, SITE VISITS & SCOPING The scope of the study was finalised after correspondence and communication with the project promoters. Site visits and surveys by the biodiversity specialist, Hoens Potgieter and public meetings facilitator, John Pallett also confirmed the scope of the project. The layout of some components of the mine have changed in line with suggestions and recommendations from the company geologists, the biodiversity specialist and the water study specialist. The alternatives are briefly discussed below under the project description chapter. Biodiversity site visits and surveys took place the same week as the public meeting and stakeholder engagement on August 5th, 2020. A social baseline survey was carried out for a 6km area around the site from 11th to 15th August 2020.

2.2 LEGAL FRAMEWORK All legislation, policies and guidelines that had reference to the proposed project were listed. The activities for which clearance is required for the project were extracted from the EMA Regulations. As per legal requirements, any mining activity requires the Environmental Commissioner within the Ministry of Environment & Tourism to render an Environmental Clearance Certificate (ECC) in terms of the Environmental Management Act, No 7 of 2007 (EMA).

2.3 PROJECT DESCRIPTION The aim of this report is to provide details on the proposed construction, operational, decommissioning and mine closure activities that will enable decision makers to make informed judgements regarding the development from an environmental perspective. Stakeholders too who must provide consent must know and understand the project details. This section was based on the information that was provided by the proponent.

2.4 PUBLIC PARTICIPATION PROCESS This chapter serves to inform Interested and Affected Parties (I&APs) and relevant authorities of the details of the proposed development and provide them with a reasonable opportunity to participate during the process. Stakeholder engagement through the Public Consultation Process, is described in a later section of this report and resulted in not only information about the community and its economic activities, but also provided insightful concerns regarding the potential impacts on the environment for the envisaged project development. Comments and concerns as obtained through discussions, written submissions and focus group meetings provided a community perspective towards the proposed development as well as generated information regarding the surrounding land use. Public meetings with the local communities took place on the 3rd and 5th August 2020.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

2.5 ENVIRONMENT DESCRIPTION The ‘environment’ is defined in the Environmental Assessment Policy and Environmental Management Act as “land, water and air; all organic and inorganic matter and living organisms as well as biological diversity; the interacting natural systems that include components referred to in sub-paragraphs, the human environment insofar as it represents archaeological, aesthetic, cultural, historic, economic, paleontological or social values”. Relevant environmental data was compiled by making use of primary information from site visits, primary data through surveys, specialist reports, secondary data and stakeholder consultation. The report identified existing environmental (both ecological and socio-economic) conditions of the receiving environment in order to determine environmental sensitivities. Information regarding the biophysical and socio-cultural environment was sourced from a number of studies previously done in and around the Opuwo and Otjimuhaka area. Fauna, flora, chemical and hydrological studies were carried out by specialists.

2.6 IMPACT ASSESSMENT The scoping and assessment process aims to guide and promote sustainable and responsible development but not to discourage development. Project components which present unacceptable or very high impact ratings have been highlighted and possible alternatives or measures were suggested. This section outlined and assessed the potential environmental impacts of the project. Potential environmental impacts and associated social impacts were identified and addressed in the report. The EAP has assessed all likely positive and negative impacts environmental and social impacts at the local and regional (Kunene Region) and national (Namibia) levels using an adaptation of the ‘Hacking Assessment Method’. Possible enhancement measures have been listed for those positive impacts while prevention, mitigation and rehabilitation measures have been provided for negative impacts. The environmental assessment was conducted to comply with Namibia’s Environmental Management Act other legal requirements applicable to the development and Namibia. The assessment process involved merging of various information streams into a description of the environment and the proposed project. If the environmental commissioner finds that the assessment of potential impacts and the proposed mitigation measures proposed in this report, are acceptable, an ECC may be awarded.

2.7 ENVIRONMENTAL MANAGEMENT PLANNING (EMP) This task involved the drafting of a standalone document that outlined the management, monitoring and mitigation measures that will avoid, minimise and/or mitigate potentially negative impacts. In some case remediation and rehabilitation will be required. The ECC should refer to the EMP, and the conditions stipulated therein, thus rendering the EMP a legally binding document to which the proponent must adhere.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

3 ADMINISTRATIVE, LEGAL AND POLICY REQUIREMENTS To protect the environment and achieve sustainable development, all projects, plans and programmes deemed to have adverse impacts on the environment require an ECC, as per the Namibian legislation which lists specific activities that need to apply for such clearance. The establishment and expansion of the sodalite mine and base and rare element operations with associated material processing falls within the range of these activities as mentioned above. The relevant project activities for which an ECC application must be made (listed as per Government Notice No 29 of 2012) are included in Table 1 below: Table 1. Applicable EMA listed activities Activity Activity Applicability No.

1 b The construction of facilities for the transmission Construction of a powerline from of electricity the Swaartbooisdrif substation to the mine.

2.1 The construction of facilities for waste sites, Provision of ablutions on site for treatment of waste and disposal of waste. staff. Creation of a waste rock dump on site (topsoil stock piles included) Wet mineral Tailings Storage Facility (TSF) included

2.2 Any activity entailing a scheduled process The site crushers, mills, will be used referred to in the Atmospheric Pollution on site. Prevention Ordinance 1976 A permit in terms of the Atmospheric Pollution Prevention Ordinance of 1976 is required

2.3 The import, processing, use, recycling, temporary Provision of ablutions on site for storage, transit or export of waste staff Storage of waste oil for recycling

3.1 The construction of facilities for any process or Establishment of a mine, a activity which requires a licence, right or other processing plant and accessory form of authorisation, and the renewal of a works area licence, right or other form of authorisation in terms of the Mineral (Prospecting and Mining Act of 1992.

3.2 Other forms of mining or extraction of any natural Quarrying activities are a form of resources whether regulated by law or not. extraction of a natural resource.

The clearance of forest areas, deforestation, The removal of trees will be done in 4 afforestation, timber harvesting or any other association with the Directorate of related activity that requires authorisation in Forestry who issue permits

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

term of the Forest Act, 2001 (Act No. 12 of 2001) or any other law.

8.1 The abstraction of ground or surface water for Water will be abstracted from: industrial or commercial purposes. 1. The Kunene River and conveyed to the mine site via a pipeline; and 2. A borehole / well in the Ondoto river.

9.1 The manufacturing, storage, handling or Storage of fuel on site and handling processing of a hazardous substance defined in of explosives for blasting purposes. the Hazardous Substances Ordinance 1974

9.4 The storage and handling of a dangerous goods, Petroleum Products Regulations No including petrol, diesel, liquid petroleum, gas or 2000: Section (3) (2) No person shall

paraffin, in containers with a combined capacity possess or store any fuel except of more than 30 cubic Meters at any one location under authority of a licence or a certificate

9.5 Construction of filling stations or any other facility Petroleum Products Regulations No for the underground and aboveground storage of 2000: Section (3) (2) No person shall dangerous goods, including petrol, diesel, liquid, possess or store any fuel except petroleum, gas or paraffin. under authority of a licence or a certificate

Additional pertinent legislation sets and policies which have (generally) informed the EA are listed in Table 2. Reference is made regarding the applicability of each law to this project. Please note that permit application procedures required for hazardous waste materials handling are not available from any governmental department; therefore, MEFT is urged to indicate which ministry is to be contacted and which process must be followed for this. Air pollution in Namibia was governed by the Atmospheric Pollution Prevention Ordinance (No. 11 of 1976) which mainly focused on the impact of air pollution emitted from point sources on occupational health and safety. It was limited in that it did not consider the impact of emissions from multiple air pollution sources on the surrounding environment nor did it address ambient air quality issues. The Atmospheric Pollution Prevention Ordinance (No. 11 of 1976) was then replaced by the Pollution Control and Waste Management Bill which considers emissions from multiple air pollution sources and their impact on the surrounding environment. Although the bill makes provision for air quality standards, Namibia does not have any air quality standards that can be implemented at present. Therefore, according to Article 144 of the Namibian Constitution, international standards may be adopted. Namibia’s Environmental Assessment Policy for Sustainable Development and Environmental Conservation (1995) as well as the Draft Procedures and guidelines for EIA & EMP of 2008 requires the following steps in an Environmental Impact Assessment Procedure: 1. Project identification & conceptualisation 2. Appoint work to an environmental assessment practitioner 3. Development of proposal through consultation 4. Application with baseline scoping report and draft environmental management plan 36

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

5. Notification with baseline report and terms of reference for full EIA 6. Review of applications & registrations 7. Full investigation, EIA Report and draft environmental management 8. Mitigation plan(s) 9. Application with full EIA and draft environmental management plan 10. Conditions and approval 11. Record of Decisions 12. Appeal (if necessary) 13. Implementation of proposal 14. Monitoring, auditing and ongoing mitigations The legal matrix of the project not only promotes sustainable development, but does so within the consideration of local, regional and national planning and development initiatives. It further serves to ensure that the health and safety of communities and workers are brought into the EMP. These procedures will be followed for the project described in the following section.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Table 2. Additional National and International Legislation

Legislation / Policy Summary Applicability to Assessment Included in Report

National Legislation

The Namibian ➢ Promote the welfare of people, All proposed development should aim at Principles of sustainable Constitution ➢ Incorporates a high level of environmental promoting the welfare of all people in a development and protection protection, sustainable manner. of the environment are ➢ Incorporates international agreements as part enshrined in the objectives of Namibian law. and goals of impact minimisation for adverse impacts.

Environmental ➢ Defines the environment, The proposed project is listed in the EMA The project has been Management Act ➢ Promote sustainable management of the regulations which require an application registered with MET and the environment and the use of natural resources, for an ECC. final EIA and EMP will be Act No. 7 of 2007, ➢ Provide a process of assessment and control of submitted in support of an Government Notice activities with possible significant effects on the ECC application. No. 232 of 2007 environment. Table 1 lists the activities requiring an ECC.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Legislation / Policy Summary Applicability to Assessment Included in Report

National Legislation

Soil Conservation Act ➢ Law relating to the combating and prevention of Infrastructure development of the Principles of soil conservation soil erosion, the conservation, improvement proposed project will inevitably impact on and pollution prevention have (Act No. 76 of 1969) and manner of use of the soil and vegetation the soils and further pose risks to soil been included the EMP which and the protection of the water sources contamination in the construction and will be submitted in support Namibia. operational phases. of an ECC. ➢ This Act covers the prevention and combating of soil erosion; the conservation, improvement and manner of use of the soil and vegetation; and the protection of water sources.

The Water Act ➢ Remains in force until the new Water Resources Water will be used during the construction, Mitigation measures relating Management Act comes into force, operational and decommissioning phases. to water contamination are Act No. 54 of 1956 ➢ Defines the interests of the state in protecting Ground water will be abstracted from a described in the EMP for the water resources, borehole; in such instance a water construction and operational ➢ Controls the disposal of effluent, abstraction permit is required. A water phases. ➢ Draft regulations are being reviewed registration / permit is also required for the disposal of waste water into a French drain. Regulations about proximity to rivers are relevant.

Water Resources ➢ Provide for management, protection, Water will be used during the construction Mitigation measures relating Management Act development, use and conservation of water and operational phases for construction to water contamination are resources, purposes as well as sewage management. described in the EMP for the Act No. 11 of 2013 ➢ Prevention of water pollution and assignment of No water will directly be sourced from a construction and operational liability, river or dam. phases. Permits for ➢ Not in force yet. abstraction are needed.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Local Authorities Act ➢ Define the powers, duties and functions of local EMA requires public participation inclusive Local and regional offices authority councils, of NGO’s, local and regional government have been invited to Act No. 23 of 1992, ➢ Regulates discharges into sewers. and IAPs. participate in the application Government Notice process. No. 116 of 1992

Public Health Act ➢ Provides for the protection of health of all The proposed project may have health Health and safety measures people. impacts on labourers and surrounding have been incorporated into Act No. 36 of 1919 communities during the construction and the EMP of the proposed operational phases. project

Labour Act ➢ Provides for Labour Law and the protection and The proposed project will require labour Measures to ensure that the safety of employees, during the planning, construction, requirements of the labour Act No 11 of 2007, ➢ Labour Act, 1992: Regulations relating to the operational and decommissioning phases. act are MET have been Government Notice health and safety of employees at work included in the EMP. No. 236 of 2007 (Government Notice No. 156 of 1997).

Electricity Act, 2007 ➢ The Electricity Act aims to establish the The proposed project will obtain electricity Health and safety measures (Act No. 4 of 2007) Electricity Control Board and provide for its produced from diesel generators on site. for the use and storage of fuel powers and functions; to provide for the on site have been requirements and conditions for obtaining incorporated into the EMP of licences for the provision of electricity; to the proposed project provide for the powers and obligations of licensees; and to provide for incidental matters. Under section 17, no person may establish or carry on any undertaking for - ➢ (a) the generation of electricity; ➢ (b) the trading of electricity; ➢ (c) the transmission of electricity; ➢ (d) the supply of electricity; ➢ (e) the distribution of electricity; ➢ (f) the importation of electricity; or ➢ (g) the export of electricity,

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

➢ Unless such person holds a licence issued under this Act that authorises the particular activity. ➢ Roadworthiness, Road Traffic and ➢ Provides for the control of traffic on public roads As part of the Health and ➢ Fitness for drivers, Transport Act and the regulations pertaining to road transport. Safety mitigation measures in ➢ Loads on Vehicles, the EMP: Road traffic signs to Act No. 52 of 1999 ➢ Transportation of Dangerous good, be erected during the Government Notice ➢ Road traffic signs, construction phases and No 282 of 1999 ➢ All construction vehicles to adhere to maintained during the the provisions of the act. operational phase.

National Heritage ➢ Provides for protection and conservation of Although no sensitive archaeological or Chance find procedures of Act places and objects of heritage significance and heritage features have been identified in possible heritage / the registration of such places and objects. the area, such artefacts may be discovered archaeological finds have Act No. 27 of 2004, during excavation activities. been included as a condition Government Notice to be conducted in the EMP. No. 287 of 2004

Explosives Act ➢ Regulations for safe storage and handling In as much as the proponent will make use Reference is made to the ➢ The magazines have to be licenced as required of explosives during mining, it will need to regulations in the EMP. Act 26 of 1956 (as by Section 22. The quantity of explosives and the be aware of the provisions of this Act and amended in SA to manner in which it is stored has to be approved its licensing requirements. April 1978) by an inspector. The inspector has powers to enter the premises at any time to conduct inspections regarding the nature of explosive, quantity and the manner in which it is stored. All explosives and residues are to be removed or destroyed in accordance regulation.

Hazardous ➢ Applies to the manufacture, sale, use, disposal Various hazardous substances will be used Handling, storage and Substances and dumping of hazardous substances as well as during the construction, operational and disposal of such substances Ordinance their import and export. decommissioning phases of the proposed have been identified as per project. specific impacts as per the EIA and EMP which details

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Ordinance No. 14 of ➢ Aims to prevent hazardous substances from management measures for 1974 causing injury, ill-health, or the death of human hazardous substances beings. throughout the project.

Pollution Control and ➢ Not in force yet, Various waste streams will be generated Waste manage measures Waste Management ➢ Provides for prevention and control of pollution during the construction, operational and have been highlighted in this Bill (draft document) and waste, decommissioning phases. These include report and management ➢ Provides for procedures to be followed for possible chemical and physical pollution. measures have been included licence applications. in the EMP.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Legislation / Policy Summary Applicability to Assessment Included in Report

International Law

Stockholm ➢ Recognizes the need for a common outlook and The proposed development is situated in Identifying potential impacts Declaration on the common principles to inspire and guide the the Kunene Region amongst people with of the project. The EMP has Human people of the world in the preservation and world heritage interest or status. measures to mitigate negative Environment, enhancement of the human environment. impacts and enhance positive Stockholm 1972. impacts

United Nations ➢ The Convention recognises that developing Some emissions may be released during the Emissions are planned to fall Framework countries should be accorded appropriate construction and operational phase of the outside of the World Health Convention on assistance to enable them to fulfil the terms of proposed development. Standards. Should such Climate Change the Convention. paraMETers be exceeded all (UNFCCC) necessary steps are to be taken to reduce emissions as mentioned in this report.

Convention on ➢ Under article 14 of The Convention, EIAs must be Although the proposed project will be Aspects of the biodiversity has Biological Diversity, conducted for projects that may negatively developed on previously disturbed areas been included in this report Rio de Janeiro, 1992 affect biological diversity. (portion of claims mined already) the site and EMP. still has sensitive features.

United Nations ➢ Aims at land management and combating Infrastructure development of the Principles of soil conservation Convention to desertification/land degradation to contribute proposed project will impact on the soils and pollution prevention have Combat to the conservation and sustainable use of and further pose risks to soil contamination been included the EMP which Desertification biodiversity and the mitigation of climate in the construction and operational phases. will be submitted in support (UNCCD) change. of an ECC.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

4 PROJECT DESCRIPTION

4.1 PROJECT RATIONALE / NEED AND DESIRABILITY The proposed activity focuses on the specific resources of sodalite, iron ore and rare earth mineralisation and mining will take place within the boundaries of known mineralisation within the ML40 and any mining claims that the Proponent currently has rights to. The product from the rare earth and iron mineralisation is envisaged in the form of mineral concentrates for the Southern African and international market. Sodalite is produced in the form of lumps of ornamental stones and as blocks of dimentsion stone. This is in line with the provisions of the Minerals (Mining and Prospecting) Act of 1993, where sodalite is categorised in the commodities of dimension stones and semi-precious stones. The mineralisation is unique in Namibia. Sodalite occurs in bright colours (mostly blue), making it a sought-after mineral and that is well known in the dimension stone and in the semi-precious stone trade for tiles, carvings and jewellery. Worldwide, significant deposits are restricted to only a few localities in Canada and the US, Brazil and Bolivia in South America and in Burma and Russia. This project will contribute to the Kunene region’s economy, and in doing so, will contribute to the socio-economic development in the area by providing jobs and providing opportunities for continued diversification of economic activities. The project is considered to be a small operation. Potential direct benefits of the combined project include: ➢ Direct capital investment ➢ Stimulation of economic development (e.g. ongoing supply of materials and goods for construction purposes; new businesses, employment, housing, better markets and access to public services etc.). ➢ Skills development and employment (an average of 55 unskilled works will be employed during the operational phase. ➢ Foreign exchange earnings ➢ Value adding to Namibian raw materials Potential indirect benefits of the project include: ➢ Expansion of trade and industrial activity in the town and region. ➢ Inducement of additional investments ➢ Diversification of the regional and national economy.

4.2 NATURE & SIZE OF THE PROJECT This ML40 area lies approximately 130 km northwest from Opuwo and is located about 2.5 km south- west of the Namibian-Angolan border, marked by the river Kunene, and 4 km south-west of the settlement Otjimuhaka (previously Swartbooisdrif). ML40 comprises an area of about 625 hectares and is covered by a section of the topographic map 1:50,000 Swartbooisdrif (sheet 1713BD). The mining area is situated on the foothills of the NE-striking ridges of the Zebra Mountains in the northwest. It covers approximately 600m of the ephemeral stream Ondoto. Figure 3 renders a map of the mining licence 40 show the corner coordinates. The Proponent plans to produce up to 12 000 tonnes / annum of sellable mineral product in the form of sodalite in the form of lumps of ornamental stone and blocks of dimension stone and as iron and rare earth concentrates from the mining licence. The activities extend beyond the mining licence and accessory works area and include the transport route along which the run of mine will be hauled, the transport of products and the storage and handling of the product at the Port of Walvis Bay. The existing main quarry of sodalite is rendered by the images in Figure 4.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Figure 3. Location of ML40 showing corner coordinates.

Figure 4. Images depicting the main existing sodalite quarry (ground and aerial image)

4.3 LOCATION DETAILS The mining licence area is located within the Kunene Region and in the northern Epupa Constituency. The mining licence area is about 125km north of Opuwo travelling along the C43 and D3701 roads and about 80 kilometres west of Ruacana along the D3700 road. Figure 5 renders a map of the location of the mining licence wiithn the Kunene Region relative the major towns.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Figure 5. The location of the Mining Licence (ML) 40 relative to Opuwo.

4.4 ACCESSIBILITY Access to the mining licence site from the district road is along existing single-track gravel roads that were constructed most likely by hand through the clearing of the bush. The district roads are two- way gravel roads. From Opuwo or Ruacana to the port of Walvis Bay the road is mainly tarred with a few stretches of gravel from time to time. Some parts of the gravel road are washed away by floods. These sections will need repair to make it possible for getting supplies to site and for large product haulage trucks to travel safely to the Walvis Bay harbour. Table 8 in the product transport section below lists the preferred and alternative haul road from the mine site to the Port of Walvis Bay.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

4.5 PROPOSED PROJECT PLAN The following is the summary of envisaged development with mining and processing activities that are expected to be undertaken by the project proponent during different project development phases.

4.5.1 Construction Phase Activities This will comprise of the following: ➢ Construction of a new processing facility for iron and rare earth ore) and associated Tailing’s Storage Facility (TSF) and Waste Rock Dump (WRD) (Figure 6 to Figure 9).

➢ Construction of stormwater canals, diversions & contamination containment (Figure 8). ➢ Construction of a water pipeline from the Kunene river to the processing plant (Figure 6 & Figure 27). ➢ Construction of a powerline from Otjimuhaka sub-station to the processing plant (Figure 6) . ➢ Construction of roads (internal within the Mining Licence) and upgrading an access road from the mine to the main road (Figure 2). ➢ Construction of fuel storage and dispensing facilities, fencing, security and staff accommodation, sewerage, and waste handling facilities.

Figure 6. Map rendering the approximate routes of the linear infrastructure.

4.5.1.1 New Processing Plant, TSF and WRD The new processing plant, TSF and WRD have been located at a new location away from the existing sodalite processing area was mainly due to its proximity to the Oroutumba community. Figure 7 renders a location map of the new processing plant, TSF and WRD relative to the Oroutumba settlement which grew around the existing Sodalite accessory works area and main quarry. Figure 9 renders a detailed plan of the new accessory works area with the various processing and mineral waste storage areas. The accessory works area was extended into the adjacent exploration area outside

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

ML40 as depicted in Figure 7. The TSF for the new processing plant is located in accord with the recommendations of the specialist studies. The fauna and flora study as well as the water study components as discussed in chapters 6 and 7 have advised that this new site that was chosen is best from a biodiversity and groundwater contamination and flooding perspective. An application was made with MME for the accessory works area and Figure 9 renders a detailed map of the originally planned components at the time of the application. Since the initial accessory works area application there has been a planned extension of the works area as per Figure 7. The water study has recommended an additional mitigation to protect the water course from potential contamination which includes a diversion canals and containment dam below the TSF and WRD. These form part of the flood damage protection measure as well. The other reason for the location of the new processing plant is the presence of trace amounts of radioactive thorium which may accumulate during processing of the ore. This concentration of radioactive species within the product is potentially dangerous to humans. Radiation protection measures will need to be applied regardless of the more remote location of the plant and TSF

Figure 7. New processing plant area showing water pipeline extension from Oroutumba settlement.

4.5.1.2 Stormwater Canals, Diversions & Contamination containment The planned locations for the diversion canals, embankments and containment dam around the new processing plant are rendered in Figure 8. These measures are in case of a 1 in 100 year flood event. The design flood protection for the Processing Plant, TSF and WRD area is detailed in Table 3. The design provides the flood protection should a peak discharge of 2.15m³/sec occur during a 1 in 100 year flood. All surface water diversion, storage and spill way infrastructure have been been designed to handle the peak discharge. This design is taken from the specialist water study by Sarma (2021). Diversion canals must be capable of safely diverting the peak discharge flow rate to a dam location. The canal will be trapezoidal in cross-section and have a maximum horizontal slope of 0.005m/m in order to limit erosion. The Containment dam will be constructed as an earth embankment dam with a minimum capacity of twice the mean annual runoff (MAR) of the catchment as calculated using the Unit Runoff Method. The dam must be constructed with a large surface area in order to maximise the evaporation potential (See Table 4).

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

The Processing Plant, TSF and WRD area is in the south western corner of ML40 and interferes with a minor river course from the south. To limit storm water entering the area, an embankment/canal will be required to divert incoming storm water to the east of the area. An embankment/canal to the north will prevent runoff generated by the Processing Plant, TSF and WRD area from entering the river course (Figure 8). This structure will separate flow from the west via a minor channel towards the Containment dam and keeping it away from any residences to the north. Incoming storm water entering the ML40 from the east will be diverted and deposited into the river course below the Containment dam and allowed to proceed northward (Figure 8).

Figure 8. Proposed locations of surface runoff diversion and containment dam, processing and TSF and WRD areas (Sarma, 2021) Table 3. Design Flood Calculations – Processing and TSF Area CATCMENT AREA (A) 0.29 km2 LONGEST WATER COURCE LENGTH (L) 0.76 km

HEIGHT AT SOURCE (H1) 822 m

HEIGHT AT DAM (H2) 803 m CATCHMENT SLOPE (S) 2.5 % M.A.P 325 mm TABLE 1: C1 (Semi-Arid) 0.65 TABLE 2: C2 1 RUNOFF COEFFICIENT: C 0.65 TIME OF CONSENTRATION (h) 0.22 hour TIME OF CONCENTRATION (min) 13.33 min RETURN PERIOD 100 years TABLE 4: MAX 24h RAINFALL (mm) 110 mm TABLE 5: RAINFALL INTENSITY (mm/h) 70 mm/h PEAK DISCHARGE (Q) 3.67 m3/s

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Table 4. Containment dam sizing - Processing and TSF Area Catchment Area (km²) Unit Runoff(mm) MAR (m³/yr) Design Capacity (m³)

Process Area 0.29 8.05 2,334 4668.42

Table 5. Dam Spillway Design – Processing and TSF Area SPILLWAY DESIGN (TRAPEZOIDAL) water study reference water study reference FLOW DEPTH (Y) 1.1 0.7 m CROSS SECTIONAL AREA (A) 2.09572 3.99 m2 WETTED PERIMETER (P) 3.8104 6.979899 m TOP WIDTH (W) 2.5399 6.4 m

BOTTOM WIDTH (B) 1.2705 5 m SIDE SLOPE (Z) 0.57 1 HYDRAULIC RADIUS 0.55 0.5716415 m

HYDRAULIC MEAN DEPTH (DM) 0.83 0.6234375 m

HORISONTAL SLOPE 0.005 0.005 m/m Nature of channel MAN N (Table 7.1) 0.025 0.05 MAXIMUM FLOW (Q) 3.979 3.8866049 m3/s FLOW VELOCITY (V) 1.899 0.9740865 m2/s MAX PERMISSIBLE VELOCITY 2 2 m2/s (water study reference)

The containment dam spillway design is compiled using the following criteria and details as given in Table 5 based on the specialist water study (Sarma, 2021): ➢ Trapezoidal in cross-section ➢ Max horizontal slope – 0.005 m/m ➢ Maximum side slope – 1:1Maximum permissible velocity (Erodible Channels)- 2m/s

4.5.1.3 Boreholes, Pumps, Water Pipeline and Water Reservoirs KNL currently abstracts ground water from a soft sediment water compartment in the Ondoto river opposite the Oroutumba settlement. Development of linear infrastructure for pumping water from the Kunene river is planned. A main supply pipeline will convey water from a borehole near the Kunene River (Figure 27) to an elevated storage reservoir above the quarry at Oroutumba. The pipeline will be approximately 3.36km with an elevation difference of 110m. Figure 6 shows the pipeline route. The route is kept reasonably straight to reduce length and therefore friction loss. A detailed pipeline design with costing will have to be carried out. However, a preliminary sizing analysis was carried out to get a better understanding of the required infrastructure. Table 6 provides the best option using High-density polyethylene (HDPE) pipe material of 110mm nominal diameter. As can be seen, the 110mm option results in a flow speed of 0.66 and 0.61 m/s and a total required head (elevation + friction losses) of 131.12m from the river level.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

HDPE Pipe class UPCL16 (can safely operate under pressure of up to 160m) is relatively common and therefore less expensive than any custom manufacture higher classes. The 110mm HDPE option (with a single lift pressure requirement of 131.12m) is therefore advisable. The lower section of pipeline installed with a standard class 16 pipe will eliminate the need for a booster pump station and water can safely be conveyed with a single lift from the river level. Table 6. Preliminary Pipeline Sizing ML40 Main Pipeline Design - 110mm Outlet Length Total L Flow Velocity Pipe Di Pipe di (ID) PN Fric Other Static H Total H Heights no (m) (m) (m³/h) (m/s) mm (mm) (m) 5% F (m) (m) (contour) Storage 3.00 840.00 Bend 1100 1100 15.00 0.61 110.00 93.30 13 4.915 0.2457 90.00 98.16 750.00 Pump TOC 2260 3360 15.00 0.66 110.00 89.45 16 12.345 0.6173 20.00 131.12 730.00 Table 7. Estimated Pump Station Power Requirements Power (10hrs per Mototr Eff System Eff Flow Rate Fluid Dencity Gravity Option Pump Head (m) Pump Eff (%) Absorbed day)kWh/Ann (%) (%) (m3/hr) (kg/m3) (m/s2) (kW) um 1 131.12 80 75 60 15.00 1000 9.8 8.92 32,571 Table 7 above indicates calculated power requirement for 110mm HDPE option. The power absorbed is less for the 110mm option as there is lower friction loss due to the larger internal diameter of the pipe. The pump and motor efficiency has been assumed but will depend on the actual pump/motor configuration eventually installed. An additional pipeline from the Ondoto River well to the New Processing Plant and community supply point is shown in Figure 7. The supply potential from the Ondoto River alluvial aquifer is discussed in Section 5.2.1 of the water study. This supply option is for the initial development phase of the project and is discussed further in Section 10 and Section 11 of the water study. Adequate elevated storage will be required to supply enough water for between 1 and 3 days. Assuming a flow rate of 24m3/hr and pumping duration of 12 hours per day, a total of 288m3 per day will be pumped to the storage. A preliminary storage location has been identified (see Figure 27) with an elevation of 840m amsl, located within the ML40 area. From this point, a gravity distribution network can supply water to most of the site. The elevation of the site varies between 800m and 840m amsl. By placing the elevated storage reservoir on the proposed location at 840m amsl, a gravity fed supply network could in theory supply water to the majority of the current ML40 quarry sites and processing facilities at the accessory work area without the need for pressure booster pumps. The final location would however need to be placed outside of any current or future workings with a detailed supply network design done once the location has been determined.

4.5.1.4 Electrical Power Provision A new conductor path transmission line from Nampower’s Swartbooisdrift substation to the accessory works area is planned Figure 6 renders a map which shows the approximate route the powerline will follow. Prior to the construction of the new power line, the projects’ electricity requirements will rely on diesel generators.

4.5.1.5 Roads A road network exists which provides access to the various quarry sites and the town of Otjimuhaka. These roads will be maintained as required. Some internal roads, which were once small tracks will be converted to serviceable roads. As such this is applicable to the road that will access the new processing plant. 52

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

4.5.1.6 Fencing, Security, Accommodation and Waste Handling Facilities Security will be supplied on a 24-hour basis at the mine and construction sites. Construction staff will be accommodated on site at a temporary camp. Support services and any facilities established during the construction phase will either be removed at the end of this phase or incorporated into the project’s operational phase Other infrastructure required and foreseen for the project development are offices and permanent accommodation for a small portion of the work force. WRDs for mineral waste will be located alongside quarries, pits and trenches and where the least impact on flora and fauna is expected. This material could be potentially used in landscaping for rehabilitation during decommissioning of the nearby quarries, pits or other excavations. Solid non-mineral waste will be removed off site and taken to the nearest rubbish dump either in Otjimuhaka or Ruacana depending on the nature of the waste. Ablution facilities will use sealed septic tanks or wastewater treatment in a sewage plant. Sewerage sludge will be taken to the Ruacana sewerage plant periodically. Alternatively, French drains could be erected provided they are no nearer that 100m away from a water course. It is anticipated that the all the proposed construction activities will commence immediately after receiving the ECC from the MEFT and once the relevant permits and licences have been issued by the different regulatory bodies.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Figure 9. Original accessory works application showing processing plant details. 54

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

4.5.2 Operational Phase Activities Current sodalite operations use an open cast mining method. Techniques make use of modern equipment such as excavators, diamond wire saw, circular diamond cutting machines, compressor driven drill rigs, jack hammers and dump trucks. Open cast mining will be established according to good practice procedure. The mining operations comprise of the phases including site clearing, excavations – by means of drilling and blasting, digging, block cutting, removing and haulage of rock to processing plant and storage yard. The diamond cutting equipment enables extraction of industrial size blocks of sodalite dimension stone. Future planned operations will entailthe drilling and blasting of rock outcrops to a depth of 50 metres for rare earth and metal mineralisation. Multiple quarries (i.e. wedge, terrace or trench shaped) will be mined at various places within ML40 and the 6 mining claims. Quarry depth will be to about 50 m. Approximately 8,000 t of ore is expected to be removed from the ground and processed on a monthly basis. For all types of mineral ore the excavations are planned to a maximum stripping ratio of 1 : 15. Overall the maximum or total estimate of waste rock produced will be 1.5 million tons annually. Mineral waste will be deposited in waste rock dumps and a tailings storage facility.

4.5.2.1 Mineral Processing KNL has alreay established a central processing facility for sodalite dimension stone at the Oroutumba settlement. Existing quarries are dotted around the ML40 and mining claims as rendered in Figure 2. Figure 10 below shows two examples of these types of mine machinery.

Figure 10. Images of sodalite quarry machinery (block cutter on left and excavator on right) Dimension stone blocks of sodalite mineralisation are trimmed with diamond rope machines and cut into slabs. Smaller blocks and boulders are trimmed and cut into slabs and tiles. Lumps and boulders of sodalite rock are stockpiled and sold as ornamental stones. Figure 10Error! Reference source not f ound. above renders an image of the large block cutter used for trimming of blocks and the small rock stockpiles. The additonal iron ore and for rare earth mineralisation ore will be mined from the ML40 and the 6 mining claims and processed at a new processing facility away from the Oroutumbu settlement. For iron and rare earth mineralisation the ore is drilled and blasted and removed from the ground in opencast quarries. To concentrate the valuable mineral content the following process is envisaged. The iron ore processing from the Run-of-Mine ore: I. Run-of-Mine ore crushed to <25 mm

II. screen for size classification

a) fraction 40 to 25 mm: scan / sorting separation b) fraction less 25: magnetic separation

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

After mining of the rare earth containing rock processing will occur as follows: I. Run-of-Mine ore crushed to <25 mm

II. screen for size classification

a) fraction 40 to 25 mm: scan / optical sorting separation b) fraction 25 to 6 mm: magnetic sorting c) fraction less 6 mm: gravity separation process using limited amounts of water

III. Milling of concentrate

a) Flotation, using limited amounts of water b) leaching of gangue carbonate, using limited amounts of water

Up to 90 ha of footprint size are envisaged for the accessory works area to accommodate the processing, tailings disposal, product storage, loading facilities, offices, security and workshop facilities within the mining licence area. The site for the new processing plant is planned for the south western corner of ML40 (See Figure 11Error! Reference source not found.)

Figure 11. Location of the new processing plant, accessory works area with TSF, WRD, water reservoir and ore stockpile area in adjacent the mining claim.

4.5.2.2 Product Transport Blocks of dimension stone, lumps of ornamental stone or concentrates of base and rare earth element products are to be transported as bulk cargo as well as in bagged form. The viability of any mining operation, just like most industries, is particularly sensitive to the logistics concerned with getting the

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021 product to market. Different options are presently being investigated for the transport of the products to the harbour of Walvis Bay. There are currently two options for the type of truck to be used for the haulage. Either the usual 36 tonne load or a specialised 67 tonne load. At a maximum monthly production of 5,000t a total of 139 truckloads at 36t each (first option) would transport product each month. That is 5 trucks each day. The product would be transported either along the gravel road to Ruacana or via Opuwo and thereafter along the tar and gravel roads to the port of Walvis Bay. The product would either be in bulk bags on low-bed trucks or in bulk trailers with covers. A reduction in the number of trucks required for the transport could be achieved if a Performance Base Standard (PBS) trucking option is approved by the Roads Authority. The bridge study (Olivier, 2020) was undertaken to support the usage of 67 tonne payload trucks along the gravel road route from Opuwo to Walvis Bay. The bridge assessment along the preferred route was assessed for weight carrying capacity. Geometrical information of bridges was verified on site, most importantly with respect to deck thicknesses and spans. Concrete strength estimates were established by means of Schmidt Hammer tests. Maximum Safe Yield design was compared to the modelled yield induced by the PBS Smart Truck configuration. From the work undertaken (Olivier, 2020) the bridges can accommodate the load imposed by the proposed high-tonnage vehicle with ample safety margins. The envisaged PBS option aims for an allowable unit load of 67 tons. This would almost half the number of haulage trucks on the road and or reduce the frequency with which the trucks must run. Refer to Appendix L for the Olivier (2020) study and the chapter on environment description as well as the assessment chapter. Table 8 lists the preferred and alternative routes and renders the travelling distances for each leg of the routes. The preferred route would be the shortest but includes a few gravel sections amounting to half the journey. Figure 12 renders a map of the planned haulage route. The preferred route is shorter by 426 km for the round trip. Although the preferred route includes gravel road sections it is not as congested as some legs of the alternative route. Table 8. Preferred and alternative road routes for haulage trucks. Preferred route Distance Units Road Surface

Mine Site to Ruacana 80 km Via D3700 gravel

Ruacana to Kamanjab 287 km via C35 bitumen

Kamanjab to Fransfontein 84 km via C35 gravel

Fransfontein to Uis 135 km via C35 gravel

Uis to Hentiesbay 124 km via C35 gravel

Hentiesbay to c28 (Swakop) 74 km via C34 bitumen

Swakop junction to Namport 45 km Via D1984 bitumen

Total 829 km

Full cycle 1658 km

Alternative route

Mine Site to Opuwo 130 km via D3701 gravel

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Opuwo to Kamanjab 262 km via C35 bitumen

Kamanjab to Outjo 157 km via C40 bitumen

Outjo to Otjiwarongo 72 km via B1 bitumen

Otjiwarongo to Omaruru 140 km via C33 bitumen

Omaruru to Karibib 65 km via C33 bitumen

Karibib to Usakos 33 km via B2 bitumen

Usakos to Swakopmund 138 km via B2 bitumen

Swakopmund to Namport 45 km via D1984 bitumen

Total 1042 km

Full cycle 2084 km

Figure 12. The preferred haulage route for transporting the various products to the Walvis Bay port.

4.5.2.3 Walvis Bay Port Storage & Export Four bulk storage location options are available for the proponent at the Walvis Bay Harbour. Figure 13 renders a map of the layout of the storage areas at the Walvis Bay Port. For the options made available there are restrictions on how the material must be stored. Traditionally, the bulk storage area for commodities were allocated opposite berths 5, 6 and 7. Due to the proximity to the Etosha Fish Factory Bulk Plot 10 would require the product to be contained in bulk bags. This mitigation would potential apply to Bulk Plot 37 as well. Bulk Plot 17 provides for the option of undercover break bulk material and all the precautions about handling exposed product inside a potentially unventilated

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021 space must be in place. Bulk Plot 20 may also allow break bulk storage in the open. Due to the heavy nature of the product, only minor barriers may be necessary to prevent Aeolian drift of any particulates. Specific requirements by the port will be applied. A lease application will be submitted for the option that best suits the Proponent.

Figure 13. Layout of Walvis Bay Port and Locations of Bulk Storage Options (Bulk Plot No. 10, 17, 20, 37) Water supply (Figure 7) provides the two sources of water. The one source is from a borehole in the Ondoto river and the other is from a borehole in the Dwyka sediments near the Kunene River. Estimated water demand is 100,000 m³/year (or 12 m³/hour over every 24 hours). The water study by Sarma (2021) is summarised in the environment description of chapter 6 and impact assessment chapter 0. This same water study provided the following specifications for the new water supply infrastructure as discussed above in section 4.5.1.3.

4.5.2.4 Power Supply Infrastructure to get electricity from the national grid may be required for the future processing operations. A powerline extending from the Otjimuhaka (Swartboois Drift) sub station to the mine site is planned by the Proponent. The route for the powerline is shown in Figure 6. Underground cabling would not be viable for such a venture and so overhead electricity lines are to be considered. The design and construction of the powerline will be in such a way that it mitigates for limiting bird collisions. Currently, electricity for the machinery at the sodalite quarries is supplied by diesel generator equipment. Diesel will be stored at the mine site. An array of photovoltaic panels will be considered as adddition or as alternative to power generation. When making use of mine buildings and structures and also of land which is already impacted on,

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021 where suitable for the construction of the panels. Such PV installation, with an overall reduction of the mine’s footprint, would constitute an evironmentally feasable alternative to both diesel generated power and a new transmission line. Water heating would use solar energy as well to maximise the use of the sun as a renewable source of energy.

4.5.2.5 On-Site Fuel Storage Diesel storage at the mine site will consist of a bunded fuel tank system, conveniently placed and accessible for the frequent deliveries. In addition to this it is feasible for a few bunded mobile facilities to be placed conveniently for use by the mining equipment at the various active mining areas. These facilities will be of modern construction, either double-skinned or bunded to ensure spills are prevented. Delivery systems will use sealed fittings to prevent spillage. The fuel facilities should be actively manned. Lubricants will be stored in a double bunded facility which is designed for this purpose. Lubricants will be transferred to machines via reticulated network within the heavy vehicles workshop or mobile lubrication trucks. Standardised spill kits and reporting systems will be in place to deal with hydrocarbon spills. Contaminated soils will be transferred to a remediation section on site specifically designed for soil remediation.

4.5.2.6 Explosives Magazine and Use of Explosives In terms of the proper use and storage of explosive material on site, the Explosives Act of 1956 states that the proponent can only keep, store or possess explosives in such a manner and in such quantities as have been approved in writing by an inspector and shall only be stored on premises where there is an explosives factory or explosives magazine. The proponent should obtain a permit issued by an inspector of the explosive police unit and the explosives need to be kept in quantities not exceeding 500 kilograms and be stored in an isolated place. Every 120 days the proponent should furnish the Chief Explosive Inspector with information in writing as from the said date regarding the quantity of explosives in the company’s possession or custody. The proponent should bear in mind that the inspector may enter any explosives facility or explosives magazine at any hour of the day or night for the purpose of inspection and for making inquiries relative to the compliance with the provisions of this Act and its regulations, or relative to the means used therein for preserving the safety of the public or employees or for purposes of analysis or test, ask for samples of explosives or ingredients of explosives from the proponent.

4.5.2.7 Security of the Mine and Accessory Works Area Various locations and infrastructure may need to be fenced in order to control the access to the various hazardous or potentially unsafe facilities so as to prevent unauthorised persons and vehicles from entering these areas, and to keep out animals from the surrounding communal farming area. Public safety is the guiding principle behind this aspect. Security personnel may be needed from time to time.

4.5.3 Decommissioning Phase The life of the mine is set at 25 years currently. After this time, if all mineral resources are spent then it will be required to close the mine. This decommissioning phase includes the following activities: ➢ removal of processing plant infrastructure, ➢ potential sale of any permanent office and ablution infrastructure for residential use ➢ Rehabilitation of waste rock dumps and the tailings storage facility to encourage natural revegetation ➢ Secure the quarry areas and tailing facility for long term public safety (i.e. by fencing, revegation or physically changing the angle of quarry sides. ➢ Rehabilitate roads where necessary.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

➢ Re-assign electrical and water infrastructure for use by the residents. These and other aspects will be comprehensively addressed in a mine closure plan which will be developed during the first cycle of the environmental clearance certificate. This is necessary so that rehabilitation and landscaping can be be conducted as the quarries, trenches and pits are created during the life of mine. This saves money in the long term so that the rehabilitation works do not get left to the time of closure when costs might be more. The life of mine for the operations has been based on the expected demand and the size of the resource. However, this may vary significantly as the demand may fluctuate. In accordance with the EMA, the proponent is required to make funds accessible which will specifically be available and allocated for rehabilitation efforts. This fund should continually be available during the life of mine and yet also be sufficient to cover all decommissioning activities at decommissioning. The rehabilitation of the various mine landforms is to encouraging vegetation growth to reduce the effects of soil erosion and to re-establish normal ecosystem functionality after the mine closes.

4.5.4 No Go Project Option The sodalite mine has been in operation for many years and the current application will bring the ML40 environmental clearance up to date with the Environmental Management Act and environmental assessment regulations. The additional activities to the current application will ensure that the mine remains viable, maintains the employment of current staff and also to add more opportunities for the community. The additional activities will bring much needed stimulus to the country’s economy. From the environmental specialist work conducted the additional activities for ML40 will only have minimal negative impact on the environment if the mitigation methods prescibed with the EMP are effectively implemented. However, if the outcome of the assessment would have identified a fatal flaw or if the decision of the MEFT was to not grant environmental clearance, then the ‘no go’ option would result. The ML 40 operations would need to cease should this occur, and the mine would have to close. This will not only deprive the proponent an opportunity to enhance economic wealth but will also deny other key stakeholders an opportunity to earn much needed income. Furthermore, the local authority and central government agencies would not earn revenue through rates and taxes.

5 PUBLIC CONSULTATION The Environmental Management Act (Act No 7 of 2007) (EMA) and the Environmental Assessment Regulations (MEFT, 2012) require that the proponent provide the public with details of the project during a public participation process. Consultation with the public forms an integral component of an EA and enables Interested and Affected Parties (IAPs) e.g. neighbouring landowners, local authorities, environmental groups, civic associations and communities, to comment on the potential environmental impacts associated with the proposed operations and to identify additional issues which they feel should be addressed in the scoping phase. Consultation was initiated and facilitated through notification letters, site and press notices, public meetings and focus group meetings. Table 9 outlines the important dates and associated actions and meetings related to the Public Participation Process. Table 9. Important Dates and Actions Related to the Public Participation Process Date Venue Facilitator Stakeholders Confirmations, details, follow-ups

21&28 July Nation-wide The Namibian All interested parties Advertisements in public 2020 newspapers – first notice.

21&28 July Nation-wide Die All interested parties Advertisements in public 2020 Republikein newspapers – second notice. See section 5.2 below.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Date Venue Facilitator Stakeholders Confirmations, details, follow-ups

From 20 Public Mr. Shipanga Public venues (school, Photos of the site notices were July Notices shops, Opuwo Regional taken. posted on Office) notice boards

20 – 24 Email notices Philip Hooks All pre-identified July 2020 sent out stakeholders in Opuwo and Otjimuhaka GRN offices and NGOs (Appendix 1)

29 – 31 John Pallett Telephone follow-ups July 2020 with identified stakeholders for meetings in Opuwo and Otjimuhaka

Mon 3 Aug MEFT office, John Pallett MEFT – Moses Areseb Send list of all stakeholders to 2020, Opuwo (Warden, Opuwo) Moses so that they can identify any gaps and let us know. 14h30 Steve Kasaona (Ranger CBNRM, Opuwo), JP to contact:

Daniel Kafula (Director Kunene R Conservcy Chairperson, CBNRM, Opuwo). Mr Kwejo Rutjindi. 081-3471624.

Erens Kutako (Warden Okanguati Sen Game Guard Mr Regnl Services, Opuwo) Kakondo. 081-2393806.

Moses will try to secure Okanguati Chairperson Mr Kunene Consvcy Tjirambi 081-2308007. members too

Mon 3 Aug Courtesy call JP Ms Emilia Alweendo, JP to send invitation to Ms 2020, to Regional acting CRO. Alweendo. She will distribute to Council office, all other relevant ministries in 16h00 Opuwo. Meet Mr Johan Jantse (not Opuwo: sure of his position) and greet • Min Health MoHSS Mr Emanuel Nafele (MURD, Devt Planning) • Min Safety and Security

Mr Gary Nekongo (Dep • Min Home Affairs Director, MLR) • Min Works and Mr Petrus Ashipala (Dep Transport. Director, Rural Services) Ms Alweendo to notify Governor

JP to notify Ruacana Constituency Councillor (Omusati Region). Mr Shitama.

Mon 3 Aug Hon JP Hon Muharukua confirmed he 2020, Muharukua will attend Wed meeting in Otjimuhaka. Charon has been 18h30 told to notify all relevant chiefs

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Date Venue Facilitator Stakeholders Confirmations, details, follow-ups

and community leaders. He will also send out the word.

Wed 5 Aug Otjimuhaka Charon Hon Muhurukua Charon Katjiongua advertised on 2020, Primary Katjiuongua Mon 3 August over the radio. Local Tas, community 14h00 School (organising leaders and members JP asked Hon Muhurukua to the meetg), inform relevant Tas and Kunene River Matjiua community leaders. Conservancy Hengua (translator, DoF from Okanguati – MC), Mr Hennie Kakondo. Not sure about John Pallett transport. JP to help him (facilitator) share a lift.

Thurs 6 Boardroom of John Pallett Confirmed with Mr Jantse in Aug 2020 Ministry of Regional Council. Land Reform, 14h00 JP has asked Ms Alweendo to Opuwo send notification to other ministries.

Fri 7 Aug Any further John Pallett 2020 meetings in Opuwo as required

Fri 28 Aug Deadline for 2020 submission of comments to EAPs.

22 March Public Review Philip Hooks All Stakeholders and An email was sent to all 2021 registered and stakeholders containing links to interested and affected the Draft EIA Report and Draft parties EMP. An executive summary was sent as an attachment. See Appendix G.

29 March Public John Pallett Community Public Minutes of Meeting in 2021 Meeting Meeting - Otjimuhaka Appendix G

30 March Focus Group John Pallett Stakeholders Focus Minutes of Meeting in 2021 Meeting Group Meeting – in Appendix G Opuwo at the Regional Government Offices – Council Chambers

19 April End of Public Philip Hooks Work in all isues and Incorporated into the Executive 2021 review responses from Public Summary Review

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Date Venue Facilitator Stakeholders Confirmations, details, follow-ups

26 April MEFT Offices / Philip Hooks DEA and MME Submission of the Final EIA 2021 Online Portal Report and Draft EMP; Copy sent to MME

5.1 SITE NOTICES Site notices for this application were erected conspicuously to inform the public: ➢ At theOtjimuhaka Primary School where the public meeting was held in Otjimuhaka ➢ At the shops and offices in the communities of Otjimuhaka (Swartbooisdrif) and Oroutumba ➢ Kunene Regional Offices, Opuwo These notices were still present at the time of the public meeting on the 5th August 2020. Photographs of the site notices can be found in Appendix B.

5.2 PRESS NOTICES Press notices were placed in two widely distributed newspapers for two consecutive weeks providing details of the project whilst giving the public an opportunity to register as IAPs. Notices appeared in Die Republikein and the Namibian newspapers on the 21st and 28th of July 2020. Scanned copies of the newspaper notices are attached in Appendix C.

5.3 BACKGROUND INFORMATION DOCUMENT A Background Information Document (BID) was provided to the various IAPs throughout the initial public participation process. This document provides an overview and a non-technical summary of the proposed development and acts as an easy reference to the proposed project. The BID is included in Appendix D. It was distributed in hard copy format during the public meetings.

5.4 PUBLIC MEETINGS & FOCUS GROUP MEETINGS The Public meeting was held on 5th August 2020, at Otjimuhaka Primary School. Furthermore, a meeting with MEFT staff at their office in Opuwo took place prior to the public meeting in the week on the 3rd August 2020. Later in the same week, on the 6th and 7th August, addtional focus group meetings with stakeholders took place in Opuwo. A presentation was given on the project at al these meetings. The people attending were asked to give their comments on the project. The separate public consultation report summarises their comments and concerns and the document is included wtih Appendix E. The power point presentation is given in Appendix F. The comments and requests made at these meetings were minuted and these can be found in Appendix G. For the register of the stakeholders and I&APs who attended the meetings please refer to Appendix H. A second round of meetings were arranged to give the feedback on the outcome of the EIA process. The Scoping Report with Assessment was summarised and a presentation delivered to the community at Otjimuhaka and the government stakeholders at the Regional Government Offices at Opuwo. The meetings took place of the 29th and 30th of April 2021 respectively.

5.5 STAKEHOLDER NOTIFICATION The full list of stakeholders is included in Appendix H. All the I&APs were all contacted by email and invited to the public meetings. John Pallett facilitated the public consultation process and wrote up the consultation report and the minutes of these meetings for both rounds of public consultation.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

5.6 PUBLIC CONSULTATION OUTCOMES A summary of the main points of concern are presented in Table 10 below. The responses to the concerns raised during the second round of public consultation are provided in the Executive Summary. No material changes were made to the report or Draft EMP based on these final concerns as they have already been considered and mitigation measures have been incorporated in the Draft EMP prior to the public review period. Table 10. The main points of concern received from people who attended the public meetings.

Theme Summary of issues

1 Benefits to the local Various requests for infrastructure improvement, provision of community training, Corporate Social Responsibility programmes and other benefits to flow from the proposed mine to the local community and conservancy.

2 Mine infrastructure, Concerns about local people being negatively impacted, by e.g. the processes and tailings dams, dust, radiation, contamination of groundwater, and developments solid wastes.

3 Negative impacts on roads Concerns about the deterioration of the roads that will be used by heavy vehicles, and its impact on tourism.

4 Heritage issues Request for proper avoidance of sacred sites when planning the various infrastructure components of the mine.

5 Mine rehabilitation Enquiries on the plans to rehabilitate, and on the permanence of the proposed quarries.

6 Value-addition Enquiries regarding opportunities for small-scale mining or value- opportunities addition (eg gem stones) opportunities for the local community.

7 Social disruptions Concerns about the negative impacts on local people and traditions, caused by work-seekers and entrepreneurs attracted to the area.

8 Biodiversity impacts Requests for thoroughness, including liaison between the biodiversity specialist and local MEFT officials.

9 Permits and authorisations Requests from various authorities for compliance with eg Forestry permits, land and fencing authorisations, road developments, internationally shared water requirements.

10 EIA process Enquiries about the process and timeline for giving inputs, the proponent, and the need for transparency.

11 Further consultations with Requests and suggestions from the local community for ongoing the local community feedback and liaison

12 Local livelihoods Concern about impacts on local livestock farming.

13 Land use Concern about conflicting land uses with eg the conservancy and livestock operations.

14 Miscellaneous Clarifications on neighbouring mining operations, and the importance of environmental and social considerations in planning.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

5.7 PUBLIC REVIEW & REPORT FINDINGS FEEDBACK The public review period for the Draft Scoping Report with Assessment and Draft EMP took place between 22nd March and 19th April 2021. Prior to submission to MEFT and during this review period the findings of the studies were reported back to the communities and stakeholders on the 29th and 30th March 2021. Final amendments and comments were received, and the final documents were prepared and submitted to MEFT on the 26th April 2021.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

6 DESCRIPTION OF THE ENVIRONMENT This section lists the most important properties and environmental characteristics of the study area.

6.1 GEOLOGY

6.1.1 Regional Geology ML40 and surrounding area is in the Eastern Kaoko Zone (EKZ) of the Kaoko Belt, in the Kunene Region, of northwestern Namibia. The northern part of the EKZ is dominated by the Kunene Anorthosite Complex (KAC). The KAC is the largest anorthosite complex in the world, with only about 10% of the KAC in Namibia, and 90% in the south-western part of Angola. The KAC in Namibia can be divided into northwestern and southeastern bodies. The northwestern body is made up of a white massive anorthosite. The southeastern part, called the Zebra Mountain lobe, is an interlayered body, subdivided into white and green anorthosite, dark leucotroctolite, and olive-bearing anorthosite. The white and green colour of the anorthosite is due to sericitisation and saussuritisation of plagioclase and the white anorthosites are older than the dark leucotroctolites. Post-dating and bordering the KAC are several, mostly mafic to ultramafic intrusions (Maier et al., 2013). These intrusions form the so-called ‘Satellite Intrusions’ of the KAC. The magmatic rocks of this group span from dunite, peridotite, pyroxenite, gabbro, troctolite, norites, anorthosites, to syenites and alkaline granites. The eastern to southern part of the KAC in Namibia, is transected by numerous regional shear zones, striking WNW and NNW. These mylonitised shear zones are intruded by syenite, quartz syenite, calcitic and ankeritic carbonatite dykes. The volatile-rich intrusives caused intense fenitisation of the older magmatic rocks. The country rocks of the Epupa basement are heavily altered by the alkaline intrusives

6.1.2 Local Geology The project area is underlain by massive anorthosite and layered anorthosite - troctolite of the Kunene Complex. The Proterozoic age large layered intrusion is emplaced in the Archean to early Proterozoic age Epupa Complex (Figure 14 and Figure 26). The anorthosite intrusion is associated with peripheral ultramafic and mafic intrusives. The economic geology of the main magmatic phase of the Kunene Igneous Complex (KIC) is dominated by magmatic cumulates such as titano-magnetite. Titano-magnetite occurs as several meter wide and up to 100m long lenses within the anorthosites. Variable amounts of sodalite occur as lenses, layers and breccias in several of the larger carbonatite dykes, but also at the direct contact of carbonatite with anorthosite. These Sodalite-ankerite ferrocarbonatite dykes intrude into the anorthosite in the ML40 area. The dykes are emplaced along earlier syenite or lamprophyre dykes in the anorthosite country rock (Miller, 2008). Three main rock types are present in the dyke a) massive carbonatite (dolomite, ankerite and sodalite), b) the main body of ankerite with albite, titaniferous magnetite, analcite and sodalite, and c) layered carbonatite containing sodalite, ankerite, analcite, albite and magnetite. Figure 14 renders the map of the various types of carbonatite dykes. The Otjitanga REE deposit is a new discovery. The carbonatites of the area contain locally rare elements like niobium (Niobec-type), rare earth elements (Mountain Pass type) and copper-nickel- sulphide mineralisation (Phalabora-type). Most REE mineralised dykes occur over an area of about 6 km in East-West direction and 2-3 km N-S direction in the southern foreland of the Zebra Mountains. Many significant mineralized carbonatite dykes are concentrated in 4 structural zones in an E-W striking corridor of 4.7 km x 1.3 km. Dyke widths range from as little as 1cm to 10 m, with most dykes between 10-50 cm widths. The carbonatite dykes attain true widths close to 10m at the cusps of two dykes.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

In the KAC, and restricted to the white altered anorthosites, are ellipsoidal oxide concentrations consisting predominantly of titanomagnetite and ilmenite, with minor silicates and sulphides.

Figure 14. A map of the various types of carbonatite dykes discovered in and around the ML40 area.

6.2 SOILS The soils in this area are either Chromi-Leptic Cambisols or Petric Calcisols. The suitability of the soils for crop production ranges from low to moderate. The rocky and Calcisols areas have a low crop production potential. The other soil type renders a moderate crop production potential. The soils have limitations such as low cation exchange capacity, a cemented calcareous layer within 100cm or continuous rock within 100 cm from the soil surface. The project area shows overutilization by livestock, and gully erosion.

6.3 HYDROLOGY The Mining Licence 40 (ML-40) is located at an elevation of about 800 m amsl on the eastern side of the Kunene Complex anorthosite intrusives (Zebra Mountains). Topographically the area slopes north towards the Kunene River and the Namibian border with Angola. There are two main supply options available, the first is the Ondoto River System and the second the Kunene River located approximately 4km north of the project. The Ondoto River, a north flowing tributary of the Kunene River, drains the areas. The ephemeral Ondoto River channel has saturated alluvium that discharges as a perennial waterhole close to ML-40, which is the main water source for the local community. Section 6.3 is taken from the specialist study by Namib Hydrosearch (Sarma, 2021).

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

6.3.1 Ondoto River System The Ondoto River runs along the Western boundary of the project, i.e. the Mining Licence area and would be the obvious choice when considering a water supply. The immediate concern is firstly sustainability and secondly the social impact on the surrounding community if the water source is over exploited. The specialist hydrologist stated that to cover all possible water supply options, use of surface water could be considered. This could be in the form of a reservoir (dam) constructed within the Ondoto River or sub-river large enough to capture adequate volumes to sustainably supply the mine and surrounding communities. The hydrologist stated that the construction of a dam within the Ondoto River would require an indepth catchment study to determine the estimated mean annual runoff and peak flows. This option was not considered as a solution for sourcing water for the project as reasoned below. According to the 1992 study by the Department of Water Affairs, the Ondoto sub-catchment has the characteristics listed below in Table 11 and Figure 15. Table 11. Details of the Ondoto Sub-Catchment (Abstracted form Table 45 – Unit Runoff Map of Namibia) Main River Name Catchment Area Stream Vegetation Soil Type Predominant Site Name Length Type Underlying Rock ( km2) (km) Formation

1640 56 Mopane Acid Granitic/Volcanic Savannah (Granite) Rocks

River Slope MAP Altitude MAR (Mm3) UR ONDOTO Ondoto (mm) (m AMSL) (MAR/A – mm) MAX-MIN

0.00714 325 1858-852 13.200 8.049

Figure 15. Ondoto Sub Catchments.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

As can be seen in Table 11 and Figure 15 the Ondoto catchment spans over a relatively large area totalling 1,640 km2 and has the potential to yield a MAR of 13.2 Million cubic meter of water. The Mean Annual Precipitation (MAP) of the Ondoto catchment is 325mm per year. The Ondoto catchment is however located in an area with high rainfall variance. The relatively high MAP is therefore misleading. Generally speaking, the area will receive below average rainfall for long periods followed by periods of high to extreme rainfall seasons. Using this data to determine the long- term sustainability for a water supply can be risky and would require a long period of actual onsite flow monitoring. In light of the above, to sustainably utilize surface water, a reservoir (dam) large enough to hold at least three to five years' worth of water requirements (including evaporation and infiltration losses) would have to be constructed. The evaporation in this area is approximately 3,000mm per year resulting in extremely large annual losses to evaporation alone. In addition to this the Ondoto River System will generate extremely high peak flows resulting in the need for costly in-river and spillway infrastructure. Flow measurement infrastructure would also have to be constructed in the Ondoto River in order to get a more comprehensive idea of the actual onsite flow characteristics. To utilise the Ondoto River as a sustainable supply high capital intensive in-river infrastructure, i.e. a dam wall, would be required therefore rendering this option uneconomical.

6.3.2 Kunene River The Kunene River is a westward flowing perineal river located approximately 4km north of ML40. The catchment area is 107,000 km2 with an average MAR of 5,200 Million m3/year (Figure 16 and Figure 17). The river level is dependent on the discharge from the hydropower station located upstream at Ruacana but subject to seasonal flooding as can be seen on Figure 18. The minimum flow is mostly experienced in November, but the low flow is still approximately 20 m3/sec (72,000 m3/hr). The required approximately 15 m3/hr abstraction to supply the mine and surrounding communities would therefore have negligible effect on the river flow.

Figure 16. Kunene River Annual Runoff at Ruacana

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Figure 17. Kunene River Hydrograph, Ruacana. The Kunene River has an extremely high variation in flow (and river level) making river abstraction infrastructure costly and also subject to flood damage. A few options are available ranging from a floating system to wet wells. In-river infrastructure is generally extremely costly and construction timing during low water season is essential.

Figure 18. Daily Mean Discharge - Kunene River at Ruacana Considering the relatively low quantities of water required, the abstraction infrastructure would not have to accommodate large pumps but would need to be constructed large enough to handle flooding and still maintain adequate supply during the low flow periods.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

A floating raft type of system would therefore be ideal but would be susceptible to damage during high flows. A sump would also have to be built to accommodate the low flow periods as the pump intakes would still need to have adequate depth to avoid vortexes and cavitation. According to the Directorate of Rural Water Supply (DRWS), the Kunene River is relatively unpolluted with a low concentration of phosphorus as well as other nutrients. The river does however have a high sediment load making the water turbid and would therefore require filtration before use.

6.3.3 Storm Water Management Plan: Canals, Diversions & Contamination Containment The ML40 area falls within the lower section of the Ondoto catchment approximately three kilometres before reaching the Kunene River. The area receives relatively high rainfall (MAP 325mm per annum) and has a high runoff potential. A comprehensive storm water management plan is therefore imperative to prevent any dirty water runoff from processing areas, drainage from tailing storage facilities or stockpiles entering the Ondoto River System and ultimately the Kunene River. The Storm Water Management Plan will therefore focus on the preliminary infrastructure required in order to: ➢ Effectively prevent, where possible, any surface water runoff entering the ML40 area and coming in contact with any mining or processing activities, rock or material stockpiles or workings that have the potential of contaminating such water. This includes run of mine stockpile (ROM), waste rock dumps, tailings storage facility, chemical and reagents safe storage in the designated area in the south west corner of ML40. ➢ Divert, store and evaporate any surface runoff generated from any processing and workings within the ML40 area. ➢ Identify any area where additional mitigation measures will be required

6.3.3.1 Catchments within the ML40 Area There are two main catchments present within the ML40 area. Catchment 1 is indicated in green (south) in Figure 19 contributes to both incoming surface water as well as generated surface water. Catchment 2 indicated in dark red (north) in Figure 19, falls predominantly within ML40 and will therefore have limited surface runoff entering the area but will generate substantial runoff within the mining area.

6.3.3.2 Storm water entering the area Unit runoff maps produced by the Hydrology Division, Department of Water Affairs has been used to calculate the estimated MAR from each catchment. Runoff from each catchment has been divided into two parts, runoff entering ML40 and runoff generated within ML40. As can be seen in Table 13, Catchment 1 generates a relatively high MAR which drains down the south western portion of ML40 and enters the Ondoto River west of ML40.

6.3.3.3 Surface runoff from the area The same method as above has been used to calculate the MAR for surface water generated within the ML40 area. Catchment 2 generated double the amount of surface runoff than Catchment 1 within the ML40 area with a total surface runoff generated within the ML40 Mining area estimated at 47,811 m3/year.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Catchment 2

Catchment 1

Figure 19. ML40 Catchments Table 12. ML40 Catchment Areas Catchment Area within Area feeding Area below the Total catchment area ML40(km2) the ML40 (km2) ML40 (km2) (km2)

1 (Green) 1.82 3.58 0.65 6.05

2 (Dark red) 4.12 0.31 7.5 11.93

Table 13. Surface Runoff Entering ML40 Catchment Area feeding the Ming area (km2) Unit Runoff(mm) MAR (m3/yr)

1 (Green) 3.58 8.05 28,815

2 (Dark red) 0.31 8.05 2,495

Table 14. Surface runoff generated within ML40 Catchment Area within ML40 (km2) Unit Runoff (mm) MAR (m3/year)

1 (Green) 1.82 8.05 14,649

2 (Dark Red) 4.12 8.05 33,162

6.3.3.4 Areas requiring mitigation infrastructure The ML40 area has been divided into two predominant catchments with drainage paths flowing in a north-westward direction. Catchment 1 cover the southern part of ML40, and Catchment 2 covers the northern part. In the project area (Figure 20), five fenitization zones and six mineral claims have been identified where workings have occurred in the past and will be extended in the future. Catchment 1 will be affected by the Processing and Tailings Area as well as Zones 1 & 2 whereas Catchment 2 will be affected by Zones 2, 3, 4 & 5 (Figure 20).

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

The majority of the mining activities are located on a ridge line which is also the watershed between the two catchments. Surface water flowing into the excavations is therefore limited. Zone 1 (Figure 21) however will require diversion of surface water from flowing into the excavation pits hampering operations and potentially becoming contaminated. It would be impractical to try and divert and store all runoff from the fenitization Zones 2 to 5 as the areas span a long narrow ridge. A number of small diversion canals and earth dams will therefore be required on both the south and northern extents of each individual excavation where excavations are across river channels in order to prevent any surface runoff from entering the drainage lines. A similar approach can be taken for the six mining claims to the southwest and southeast of ML40. Catchment 2 contains the remainder of the fenitization zones and will require the similar individual protection discussed for Catchment 1. The potential for leaching potential of mined minerals is low and is discussed below in Section 8 and in more detail in the water study (Sarma, 2021) The Processing and Tailings area located in the south western corner of ML40 will however need a higher level of protection and storage facility in the form of diversion embankments and an earth dam (referred to as the Containment Dam in the rest of the report).

6.3.3.5 Diversion embankments and Containment dam In order to prevent the surface runoff and fines from the Processing and Tailings Area and Zone 1 entering the drainage lines, a stormwater diversion embankment, a stormwater diversion canal around the area of concern must be constructed on a contour line basis. The diversion canal and earth dam storage should be designed for a 1 in 100 year flood. The diversions will direct the water to the main channel and Containment dam. The objective will be to capture and store the storm runoff from Zone 1 and the Processing and Tailings area for a long enough period to allow the potentially contaminated water to evaporate. A spill way must however still be sized and constructed to ensure the structural integrity of the dam during longer return period floods. Dam break will result is a more severe environmental problems than an overflow scenario.

6.3.3.6 Diversion Canal, storage and spillway design criteria The extent of this study does not include final designs of the infrastructure however a detailed design criterion is included for final design purposes.

6.3.3.7 Design flood A design flood of 1/100 years was used to determine the peak discharge from contaminated areas. The Rational Method of determining the peak design flood was used. See the water study for the full details.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Figure 20 Potential excavations, processing, and tailings area in ML40

Figure 21. Area of Additional Concern – Zone 1

6.4 GROUNDWATER The groundwater study by Namib Hydrosearch (Sarma, 2021) is referenced throughout the discussion that follows. The current water supply source is an infiltration gallery on the Ondoto River alluvium. The sustainability of this scheme is dependent of the stored volume and regularity of recharge.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Recharge is dependent on rainfall that is known to be erratic in the semi-arid Kunene Region. The abstracted water from the hand dug alluvium well is utilised by the local community and so any abstraction exceeding the inflow rate into the alluvium may cause a lowering of the water table and render the hand-dug well dry, therefore putting the supply at risk. Three potential groundwater sources were evaluated, and the findings are summarised here.

6.4.1 Ondoto River alluvium The main commercial activities in the project area are dimension stone mining, artisanal scale mining of sodalite from various claims and livestock farming by the community. The only source of perennial water in the ML 40 area and immediate surroundings is groundwater in the Ondoto River alluvium. A hand dug well is operated by the proponent for supply to the camp and community. Therefore a submersible pump has been placed in the hand-dug well and water is pumped to a filter system before supply (Figure 22). The current water consumption from the well in the Ondoto River is estimated as less than 5m³/day for domestic use by the community and the company. During the hydrocensus conducted no other borehole or well was found. Livestock are watered directly at springs in the Ondoto River in places of outflow from the alluvium where the bedrock is close to surface. The community and government offices in Otjimuhaka (Swartbooisdrift) at the bank of the Kunene source water from the Kunene River. The reach of the river that includes the well forms an alluvial compartment bounded upstream and downstream by bedrock outcrops. The compartment has a length of 5,700 m and covers an area of 375,600 m². It is digitised from a Google Earth image and is shown in Figure 23. The groundwater level measured in the well is 3.9 m bgl. Assessment of the Ondoto River alluvium for water supply for the future mining and processing activities could only be done in a cursory manner from the data available. The stored resource in the alluvium compartment with assumed saturated thickness of 4m and a porosity value of 20% is 300,500m³. Further assuming that 50% of the stored volume is abstractable and the aquifer is replenished every 5 years the volume of water available is 30,000 m³/year (or about 80m³/day). The time intervals in which groundwater recharge occur is the critical factor in the sustainability of this supply. Recharge to alluvial aquifers generally occurs by vertical leakage during river flow as known from the better studied ephemeral systems of Namibia (e.g. Kuiseb, Omaruru, and Oanob). The Ondoto River is known to have highly variable flow from year to year as discussed above but actual flow monitoring data is not available for analysis. A detailed evaluation of the sustainability of the source would require measurement of the alluvium thickness over the length of the compartment, estimation of aquifer properties and flow gaging information. Notwithstanding the above constraints in the evaluation of the aquifer, the variability of river flow and recharge suggests that the overall long-term sustainability of the resource is doubtful when subjected to regular abstraction at the required rate.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Figure 22. Hand-dug well in the Ondoto River alluvium used to supply the mining camp and local community

Figure 23. Ondoto River alluvial deposit between bedrock outcrops close to Mining License 40.

6.4.2 Quality of groundwater in the project area and surroundings Groundwater sampled in the Ondoto hand-dug well is already used to supply for domestic use to the local community and exploration camp site, and for livestock watering. The overall quality of the water

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021 is categorised as Group B, Good quality water according to the water quality guidelines (MAWF, 1988). The water has temporary hardness, sodium and chloride levels exceeding Group-A level. Higher sodium and chloride (and consequently the total dissolved solids) usually results from evaporative concentration of water over time in semi-arid areas. Mixing of older water with recent recharge water of Ca-Mg–bicarbonate type and lower salinity determines the overall chemistry of the water. Iron and manganese content of the sample taken from the hand-dug well is slightly higher when compared to the supplied water at the community water point. Aeration during pumping and transfer possibly causes iron to precipitate as oxide/hydroxides and is removed during filtration before supply. Equilibrium calculations show that the well water is supersaturated in terms of calcite, dolomite, goethite, and hematite. Precipitation of carbonate and iron oxide/hydroxide phases is therefore expected. Additional physico-chemical parameters were analysed of the hand-dug well water and all analysed parameters are within maximum recommended limits (General standard limits of Article 21 permits, effluents, regulation R553, 1962). Analysed minor and trace elements are within acceptable limits. The compared limits are Cu 2 mg/l, Zn 10 mg/l, B 4 mg/l, Co 1 mg/l, Pb 0.2 mg/l (Water Quality Guidelines of Namibia, MAWF 1988) and Cu 2 mg/l, B 2.4 mg/L, and Pb 0.01mg/l WHO (2011). The above parameter values are indicative of the level to be expected naturally and should form the baseline levels for the monitoring of water quality in the future. The sodium, chloride and sulphate levels in the Ondoto River alluvium may decrease or increase depending on frequency of recharge and rate of abstraction.

6.4.3 Anorthosite of the Kunene Complex Anorthosite rocks of the Kunene Complex underlie the area with minor intrusives of alkaline rocks and altered anorthosite. The overall groundwater potential of the Kunene Complex lithologies is described as poor in the Hydrogeological Map of Namibia (. It is however not possible to evaluate the potential as there is no water drilling data from the anorthosite. The igneous rocks have very low primary porosity and higher groundwater potential will be limited to where the Complex is affected by faulting. Although several lineaments have been mapped the potential of these features to yield groundwater is unknown. Mineral exploration boreholes drilled to depths of about 100 m were dry in the mining license area. It is conceptualised that the groundwater table lies below the drilled depth (below 100 m) at ML40 and its surroundings. This is because the Kunene River is influent (losing) as is typical in arid regions and groundwater level is expected to decline south wards from the river (river level at approximately 720 m amsl). The average elevation of the mining area is 815 m amsl, some 94 m above the stage. This is illustrated in a schematic cross-section in Figure 24. Any borehole targeting groundwater in the mining area will have to be drilled deeper than 100m, probably in the range of 150-200m.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Figure 24. Schematic North-South section from the Kunene River to the south showing the conceptualised groundwater level in the bedrock With the area's proximity to a perennial river and limited water demand for activities, no drilling of water boreholes has been done in the past and the potential remains unknown. In Okanguwati, some 65km to the west of the project area, on the western side of the Kunene Complex, high yielding boreholes have been drilled in the Epupa Complex rocks.

6.4.4 Dwyka Group sediments To the north of the mining license between the east-west road to Otjimuhaka and the Kunene River, exposures of Dwyka Group sediments are present. The lithologies include tillite, mudstone and some sandstone units. The sediments and the contact with the underlying Kunene Complex anorthosite are visible in the Ondoto River cutting, immediately south of the road to Otjimuhaka. From the outcrop the Dwyka strata dips northwards towards the Kunene River. The groundwater potential of the Dwyka Group sediments is usually considered poor (e.g., central and south Namibia). The potential of sandstone units (Figure 25) within the Group and the contact zone between the Dwyka and the underlying anorthosite is however considered high as direct leakage from the Kunene River is possible. The extent of the exposed Dwyka Group is about 700m till the Kunene River channel (See Figure 26). A preliminary outline of the sub-cropping Dwyka is shown in Figure 26. There are currently no boreholes in this unit.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Figure 25. Arenaceous unit within Dwyka Group sediments in the southern bank of the Kunene River Abstraction from a single or a series of boreholes drilled within a safe distance from the river edge but still supplied by the river via lateral infiltration would alleviate the need for any in-river infrastructure and if placed correctly would not be susceptible to flood damage. Low water periods would also not be an issue as the riverbed level will still be much higher than the pump intake level with adequate hydraulic gradient to ensure adequate supply. Water quality would be vastly improved especially when considering the low pollutant but high sediment load of the river water. Therefore, water supply boreholes in the Dwyka may have the benefit of requiring little treatment and being free of suspended solids and microbiological pollution. High efficiency submersible pumps can be used so the borehole can be drilled to any depth allowing for an adequate sump to accommodate this type of pump. The exact location and potential yield would however have to be investigated further before a final decision can be made. This activity is planned for phase 2 of the project.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Figure 26. Geology of the project area (after Miller, 2008)

6.4.5 Supply Infrastructure A main supply pipeline will be required to convey water from the river / borehole abstraction infrastructure at the Kunene River. to an elevated storage reservoir. The pipeline will be approximately 3.36km with an elevation difference of 110m. Figure 27 shows the site of the borehole infrastructure, the pipeline route and elevated reservoir. The route is kept reasonably straight to reduce length and therefore friction loss. A detailed pipeline design with costing will have to be conducted. However, a preliminary sizing analysis has been complied in order to get a better understanding of the required infrastructure. Table 6 indicates two sizing options using HDPE pipe material of 110mm and 90mm nominal diameter. As can be seen, the 110mm option results in a flow speed of 0.66 and 0.61 m/s and a total required head (elevation + friction losses) of 131.12m from the river level. Option 2 is a 90mm HDPE pipe with a higher total required head of 160.51m. HDPE Pipe class up CL16 (can safely operate under pressure of up to 160m) is relatively common and therefore less expensive than any custom manufacture higher classes. The 110mm HDPE option (with a single lift pressure requirement of 131.12m) is therefore advisable. The lower section of pipeline installed with a standard class 16 pipe will eliminate the need for a booster pump station and water can safely be conveyed with a single lift from the river level.

6.4.6 Discussion on water supply options In light of the above information, the most viable option for sustainable water supply is a borehole or series of boreholes drilled close to the Kunene River into the Dwyka sandstone target lithologies. This option is not totally immune to flood damage but will also ensure adequate supply during the low flow periods with potential benefits as listed below. ➢ Water quality will be greatly improved alleviating the need for water treatment infrastructure. ➢ Efficient high pressure multistage submersible pumps can easily be installed without the need for expensive in-river infrastructure.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

➢ A detailed pipeline design will have to be drawn up but from the preliminary pipe sizing, standard 110mm HDPE pipe can be installed with standard off the shelf fittings. ➢ Water storage can be located within the ML40 Mining area with a potential pressure of 20m (2 bar) over a large portion of the area. Final location would however be dependent on the mining activities. ➢ A second reservoir near the new processing plant could be supplied by both the Kunene and the borehole/well in the Ondoto River (Figure 27).

Figure 27. Map showing the source of the water supply options, pipeline routes and reservoirs.

6.5 CLIMATE Climate data described below comprises the temperatures, wind and rainfall typical for the area. The importance of this data is for assessing the potential impacts of dust emanating from the mining process and predicting directions and intensity of emmission plumes. The direction and distance that plume travels can assist in planning the locations of mining infrastructure and the degree to which receptors might be affected.

6.5.1 Temperature Air temperature is important, both for determining the effect of plume buoyancy (the larger the temperature difference between the plume and the ambient air, the higher the plume can rise), and determining the development of the mixing and inversion layers (Liebenberg-Enslin 2019). Maximum, minimum and mean temperatures for a study area 50 km east of the mining claim are given as 34°C, 7°C and 21°C respectively (Figure 28), based on modelled data for the period 2016-2018. Average daily maximum temperatures range from 34°C in November to 25°C in July, with daily minima ranging from 14°C in March to 7°C in July. (Liebenberg-Enslin 2019)

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Figure 28. Modelled average, minimum and maximum temperatures for each month of the year for the period 2016 to 2018 for Opuwo (Liebenberg-Enslin 2019)

6.5.2 Wind The wind direction, and the variability in wind direction, determines the general path air pollutants will follow, and the extent of crosswind spreading. Wind roses comprise 16 spokes, which represent the directions from which winds blew during the period. The colours used in the wind roses below, reflect the different categories of wind speeds; the red area, for example, representing winds between higher than 5 m/s. The dotted circles provide information regarding the frequency of occurrence of wind speed and direction categories. The frequency with which calms occurred refers to periods during which the wind speed was below 1 m/s. (Liebenberg-Enslin 2019) Seasonal variation in the wind field is shown in Figure 29 with predominantly southwesterly and west- southwesterly winds during the summer months (Nov – Feb). During the autumn months (Mar – May), the westerly flow subsided with more frequent winds from the east and east-northeast. The winter months reflected predominant east-northeasterly and easterly winds with almost no flow from the westerly sector. During springtime (Aug – Oct) the easterly flow started to subside with more frequent flow again from the west-southwest. (Liebenberg-Enslin 2019) The new processing plant within ML40 has been located to reduce the impact on the Oroutumba community and the nearby dwellings. Specific behaviour of personnel can be planned to reduce exposure to dust emanating from the tailings dam and waste rock dumps.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Figure 29. Modelled wind data for the seasons from 2016 to 2001 for Opuwo (Liebenberg-Enslin 2019)

6.5.3 Rainfall Precipitation is important to air pollution studies since it represents an effective removal mechanism for atmospheric pollutants and inhibits dust generation potentials. Monthly average rainfall figures obtained from worldweatheronline.com are illustrated in Figure 30. (Liebenberg-Enslin 2019) Based on long-term rainfall data for Opuwo (1940 – 2001), the area receives between 62 mm and 837 mm. The rainy season is between December and March, with the dry season from May to September. (Liebenberg-Enslin 2019)

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Figure 30. Opuwo annual rainfall data from 1940 to 1998 (Liebenberg-Enslin 2019).

6.6 BIOLOGICAL ENVIRONMENT At the African scale the project site falls in the Savanna biome, in the stable savanna zone where the ratio between woody and grass plants is determined by climate, particularly annual rainfall below 560 mm . At the Namibian scale the site is in the Western Highlands biome, which is characterised by an Acacia Tree-and-Shrub Savanna vegetation type and a dominant vegetation structure of grassland and scattered trees (Mendelssohn, et al., 2002). The region’s biodiversity patterns are variable according to Mendelssohn et al (2002), whose ranking for plant diversity (the number of species present in an area) is given here as medium-high. On the landscape scale, the scale on which biodiversity conservation needs are addressed, endemism levels are high for many taxa because of ranges that extend from Angola south across the Kunene River (Mendelssohn, et al., 2002). At a global scale the project site falls in the Afrotropical Region for all vertebrate taxa. Anthropomorphic modification and the low density of vegetation result in a low density of large mammals. The project site falls within the Kaokoveld centre of endemism, a biogeographical region rich in endemic and range-restricted plants and animals. Because of the remoteness of the region there is a dearth of data on biodiversity, but recent discoveries of plant species underline the conservation importance of the region. The cumulative impact of mining and other development in the arid zones of Namibia and Angola means that development in such areas should be planned responsibly, and management measures implemented and monitored diligently.

6.6.1 Habitat Classification (Potgieter, 2020a) Basing a biodiversity study for impact assessment on habitats has been found to result in units that are easier to address in environmental management plans and they can also be managed more easily by mine staff during the operational phase of the project. Another advantage is that in arid zones many species of plants and vertebrates are restricted to certain habitats and are not observed during the site visit, but information on expected species of conservation concern can be extrapolated from knowledge of the habitats.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Three habitat types were identified in the vegetation and vertebrate studies for this project and were integrated in one combined floral and faunal classification (See images in Figure 31): ➢ Mopane scrub, ➢ rocky outcrops and ➢ river/drainages. It should be noted that this categorisation describes macrohabitats on ML40. It is possible that microhabitats may be discernible within any or all of these and that they could potentially require additional mitigation measures. Aspects that were considered when assigning habitat categories: ➢ Topography ➢ Substrate ➢ Vegetation structure, in terms of layers: a well-structured vegetation assemblage is represented by the presence of a high canopy, trees and shrubs of varying heights, a forb layer and a bottom layer with ground cover such as grass. The three habitat types were given sensitivity ratings, with the caveat that all habitats are sensitive to disturbance and deserving of conservation measures. The sensitivity rating was assigned based on properties of each habitat itself, including: ➢ nationally or regionally scarce habitats ➢ size of habitat, in the context of the total availability of comparable habitats in Namibia and/or the region ➢ exceptionally high diversity and/or abundance of species ➢ high level of endemism ➢ species of conservation concern are supported ➢ key ecological processes ➢ contributes disproportionately to ecological function (nutrient and energy flows) ➢ provides critical resources ➢ restorability after disturbance Human habitation, grazing and mining activities have resulted in modified areas, some of them severely degraded such as the rocky ridge south of ML40 and the quarry/mine sites (The village Oroutumba, located in Mopane scrub habitat adjacent to the Ondoto River, is also an anthropologically modified area.

6.6.1.1 Mopane Scrubland The largest part of ML40 consists of open Mopane scrubland. The topography is gently undulating, bisected by drainages and ridges topped with rocky outcrops. In the east and southeast of the study area the profile is flatter than in the west and northwest, where there are more and steeper rocky ridges. The vegetation structure varies slightly from west to east, broadly corresponding to changes in topography with larger Mopane trees and some Commiphora species in the western parts of the study area. In the east and southeast Colophospermum mopane form a scrubby open woodland of homogenous height and structure, interspersed with Catophractes alexandri. The substrate consists of loose stones and gravel on packed sand. Mopane trees are interspersed with Terminalia prunioides, Boscia microphylla, Commiphora multijuga and other Commiphora species, as well as Ceraria pedunculata and Gymnosporia senegalensis. The vegetation understorey is sparse, and grass was the only ground cover observable at the end of winter, but more annual plant species are expected to appear after rain.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

This habitat has been modified by human activities such as harvesting and livestock grazing. Both these activities are current and ongoing, and the village Oroutumba is located in a degraded area in Mopane scrub abutting the Ondoto River. Roads and accessory works will be located in this habitat. It is considered the least sensitive habitat, but care should be taken to maintain the natural flow patterns of surface water in all drainage lines.

6.6.1.2 Rocky Outcrops This habitat occurs at the top of ridges in ML40 and the surrounding area, and closely follows fenitisation, i.e. rock alteration features. The vegetation structure is layered, providing resources for a variety of animal taxa. A ground cover of grass was observed from the flora specialist work and, although no forbs were present, these will appear in summer and after rain. There is a sub storey of shrubs and a well-developed upper storey of trees, dominated by Colophospermum mopane and including Terminalia prunioides, Commiphora mutlijuga, several other Commiphora species, Sterculia quinqueloba, Sterculia africana, Moringa ovalifolia, Rhigozum virgatum, Boscia albitrunca, Boscia microphylla, Boscia foetida and Ceraria longipedunculata. It is highly likely that three recently described plant species of conservation concern could occur in the rocky outcrops: Maerua sebrabergensis, Erythrococca kaokoensis and Ocimum sebrabergensis, since the rocky ridges contain black and grey anorthosite rocks similar to the locations in the Zebra Mountains where these three species were first found. The rocky outcrops present both abundance and richness of plants that are much higher than those of the surrounding scrubland, contributing to the ecological value of this habitat. The location of the study area in the foothills of the Zebra Mountains and in the Kaokoveld centre of endemism, a biogeographical region rich in range-restricted plants and animals, further increases the sensitivity of the rocky ridges. Sodalite and the rare earth minerals are in this habitat; it is where mining will be done and where most of the irreversible impacts (drilling, blasting and open cast mining) will take place.

6.6.1.3 Rivers & Drainage Lines The Ondoto River crosses the study area for less than a kilometre, but it is an important habitat in terms of both the study area and the region because of two reasons. Firstly, the drainages on ML40 empty into the river and from here it is only six km from where it flows into the Kunene River. Secondly, it is an important source area of high diversity in an arid landscape and a resource during drought years. Any activity in the catchment (i.e. ML40) will affect the ecology of the Ondoto and Kunene rivers. At this point the river is wide with a rock face on its east bank and a flood plain to the west. This stretch of the river and its banks contain sparsely distributed large trees, few shrubs and ground cover in the form of annual plants such as grasses and forbs are expected to appear in summer and after rain. The substrate is sandy, with scattered rocks and boulders and a shallow stream. The river is an important resource for the Oroutumba community, and it has been modified by historic and current human activities such as grazing and harvesting. Cattle and goats were observed in the river, as well as daily human household activities (water collection, laundry and playing children). After rainfall events, surface water runs via ephemeral drainages from the ridges and outcrops to two large washes and eventually into the Ondoto River. The washes are expected to have surface water after rain and likely contain groundwater that sustains assemblages of perennial vegetation that are more diverse (both floristically and structurally) than the vegetation in the surrounding landscape. The substrate in this habitat consists of sand, gravel and rocks, providing habitat for burrowing reptiles and for small mammals and reptiles that rely on rocks for shelter.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Plant species in the riverbed and on its banks include Faidherbia albida, Acacia erioloba, Ficus cordata, Ficus petersii, Combretum imberbe, Ziziphus mucronata, Aloe littoralis, Acacia reficiens, Hyphaene petersiana, Boscia albitrunca, Combretum apiculatum, Gymnosporia senegalensis. In the smaller drainages, vegetation is dominated by Colophospermum mopane and also present are Acacia nilotica, Acacia reficiens, Terminalia prunioides, Commiphora multijuga and Combretum apiculatum. Riverine and drainage habitats present a high ecological value for most taxa and are considered very sensitive. Blocking of surface and/or groundwater flow will result in loss of perennial plant species and a reduction in the resources, such as food, shelter and soil stabilisation for burrows that they represent to other trophic groups. Development that is planned in this habitat includes linear structures such as roads, pipeline and power line that will cross drainages. In the Ondoto River, a new well and pump to provide water to the accessory works area are planned developments.

6.6.2 Flora (Potgieter, 2020a) The following terms of reference for the flora study were used: 1. Describe and map the existing terrestrial flora and identify their occurrence, relative abundance and distribution 2. Identify any species that are of conservation concern. 3. Provide up to date information and data on the flora and fauna within the project area (based on existing literature, expert opinion and moderate-effort fieldwork). 4. Identify key critical factors concerning the impact on biodiversity. 5. Prepare a report about the findings from the work. The mine site was visited for four days and information on the taxa included in this report is based largely on existing literature. The site visit took place in the middle of winter and there were many plant species without leaves, fruits or seeds. Most annual and some perennial plants were either absent or present but not presenting identifying characteristics, such as the Corkwoods (Commiphora spp), of which there are several species in the study area. It is possible that some factors that could affect the composition of plant assemblages or populations may have been overlooked during the site visit. Vegetation structure in the region is a shrubland-woodland mosaic, the upper storey dominated by Colophospermum mopane, Terminalia prunioides and Commiphora species. Acacia species are present in drainages and streams, and grass cover is sparse.

6.6.2.1 Habitat delineation and categorization This is described above, and the photographs of each habitat type are rendered in the specialist flora report found in Annexure I.

6.6.2.2 Species of Conservation Concern Species are potentially of conservation concern when they are endemic or near endemic to Namibia, have a threatened Namibian or IUCN status, or are legally protected in Namibia. The plants species that have been recorded in or that are expected to occur in and around ML40 are listed in the flora report. The species list was drawn up mainly from data provided by the National Botanical Research Institute (National Herbarium of Namibia, 2020) for quarter degree squares 1713 BC and 1713 BD (which include ML40), as well as from observations made during the site visit and from perusing distribution maps and habitat descriptions in the sources listed in section Error! Reference s ource not found.. of the flora report.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

The results of the vegetation study are summarised in the flora report in Appendix I and the most important points here below. Three recently described species, Maerua sebrabergensis, Erythrococca kaokoensis and Ocimum sebrabergensis are known only from a few specimens collected in the Zebra Mountains but they are likely to be found on the ridges and rocky outcrops in ML40 as well. The fact that they were found and described as recently as 2015 and 2019 illustrates both the importance of the Kaokoveld Centre of endemism and how under-collected it is in terms of herbarium specimens. This is largely a result of the remoteness and inaccessibility of much of the region and of the Zebra Mountains specifically.

6.6.2.3 Landuse and resource utilisation Livestock carrying capacity is regarded as relatively low and so the risk of farming in this area is medium (Mendelsohn et al 2002). The life stock shepherds are currently utilising the mining licence area and the accessory works area on an intermittent basis for feeding their herds, keeping their livestock safe overnight and travelling through the mining licence en route to other browsing areas or a daily water source near the mine village of Oroutumba. The subsistence farming has had some impact on the habitat functioning in terms of the availability of resources higher up the food chain. This is anecdotally or qualitatively evidenced by the intensively browsed vegetation and the absence of herbaceous vegetation in the three habitats. To what extent climate, i.e the persisting drought, has played a contributing role in diminishing the potential for re- establishment of grasses and herbaceous plants is unknown. The community subsists from the various habitats in multiple ways through the harvesting of wild fruits and or seeds and even bulbs. The veld is also a source of natural medicinal remedies and even cosmetic products. The expansion of the mine and infrastructure may have an impact on these elements. It is important that the proponent works with the community to identify the areas within the mining footprint that provide such resources and provide some means of access or compensation for loss of access to such resources if at all necessary.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Rocky Outcrops Rocky Outcrops

Mopane Scrubland Mopane Scrubland

Rivers & Drainage Lines Rivers & Drainage Lines

Figure 31. Images of the three habitat types categorised for the area

6.6.3 Fauna Potgieter (2020b) undertook the biodiversity scoping study and assessment for the proponent. The full study can be found in Appendix J. The following summary is extracted from the study, starting with a brief description of each habitat type and then a summary of the species expected to be found there. Thereafter, a sensitivity rating is discussed and finally a summary of the impact assessment. The site was visited for four days, which limited the field work to visual observations. Therefore, information on the taxa included in this report is based largely on existing literature. It is possible that some factors that could affect the persistence of species and/or composition of populations may have been overlooked during the site visit. A greater confidence is attributed to the assessment outcome

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021 for those areas the specialist observed firsthand. The fauna specialist categorised and delineated the landscape into three habitats. Figure 32 renders a map of the delineation of the categorised habitats.

Figure 32. Map of habitats in the study area The third habitat type, Mopane woodland, covers the unshaded remainder of ML40 (red outlined area) The habitats were rated as to their sensitivity, with the caveat that all habitats are sensitive to disturbance and deserving of conservation measures. A sensitivity rating was assigned based on properties of the habitat itself, including: ➢ nationally or regionally scarce habitats ➢ size of habitat, in the context of the total availability of comparable habitats in Namibia and/or the region. ➢ exceptionally high diversity and/or abundance of species ➢ high level of endemism ➢ species of conservation concern are supported ➢ key ecological processes ➢ contributes disproportionately to ecological function (nutrient and energy flows) ➢ provides critical resources ➢ restorability after disturbance

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

6.6.3.1 Rocky Outcrops This habitat comprises rocky outcrops at the top of rocky ridges in ML40 (black in Figure above), and closely follows fenitisation in the area. The vegetation structure is layered, providing resources for a variety of taxa. A ground cover of grass was observed and although no forbs were present, they will appear in summer and after rain. There is a sub-storey of shrubs and a well-developed upper storey of trees, dominated by Colophospermum mopane and including Terminalia prunioides, Commiphora mutlijuga, several other Commiphora species, Sterculia quinqueloba, Sterculia africana, Moringa ovalifolia, Rhigozum virgatum, Boscia albitrunca, Boscia microphylla, Boscia foetida, and Ceraria longipedunculata. Structured habitats potentially support a large diversity of birds, especially insectivores, and are possibly essential for many invertebrate taxa. Large boulders and rocks, shrubs, annual plants and detritus combine to offer high niche diversity that sustains high species diversity, particularly for invertebrates, reptiles and habitat-specific small mammals. It is highly likely that three recently described plant species of conservation concern would occur in this habitat: Maerua sebrabergensis, Erythrococca kaokoensis and Ocimum sebrabergensis, since the rocky ridges contain black and grey anorthosite rocks similar to the locations in the Zebra Mountains where these three species were first found. The rocky ridges present both abundance and richness of plant species that are much higher than those of the surrounding woodland, contributing to the ecological value of this habitat. The location of the study area in the foothills of the Zebra Mountains and in the Kaokoveld centre of endemism, a biogeographical region rich in range-restricted plants and animals (Swanepoel, 2015), further increases the sensitivity of the rocky ridges. Sodalite and the rare earth minerals are in this habitat; it is where mining will be done and where most of the irreversible impacts (drilling, blasting, open cast mining) will take place.

6.6.3.2 River & Drainage Lines The Ondoto River crosses the study area for less than a kilometre, but it is an important habitat in terms of both the study area and the region because of two reasons. Firstly, the drainages on ML40 empty into the river and from here it is only six kilometres from where it flows into the Kunene River. Secondly, it is an important source area of high diversity in an arid landscape and a resource centre during drought years. Any activity in the catchment (i.e. ML40) will potentially affect the ecology of the Ondoto and Kunene Rivers. At this point the river is wide with a rock face on its east bank and a flood plain to the west of the ML40. This stretch of the river and its banks contain sparsely distributed large trees, few shrubs and ground cover in the form of annual plants such as grasses and forbs are expected to appear in summer and after rain. The substrate is sandy, with scattered rocks and boulders and a shallow stream. Plant species in the riverbed and on its banks include Faidherbia albida, Acacia erioloba, Ficus cordata, Ficus petersii, Combretum imberbe, Ziziphus mucronata, Aloe littoralis, Acacia reficiens, Hyphaene petersiana, Boscia albitrunca, Combretum apiculatum, Gymnosporia senegalensis. This habitat has been modified by historic and current human activities such as grazing and harvesting. Cattle and goats were observed in the river, as well as daily human household activities (water collection, laundry and playing children). Development planned for this habitat is a new well and pump to provide water to the accessory works area (Figure 7). Riverine habitats present a high ecological value for most taxa and are generally considered very sensitive. After rain, surface water runs via ephemeral drainages from the ridges and outcrops to two large washes and eventually into the Ondoto River. The washes are expected to have surface water after

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021 rainfall events and likely contain groundwater that sustains assemblages of perennial vegetation that are more diverse (both floristically and structurally) than the vegetation in the surrounding landscape. The substrate in this habitat consists of sand, gravel and rocks, providing habitat for burrowing reptiles and for small mammals and reptiles that rely on rocks for shelter. Vegetation is dominated by Colophospermum mopane and also present are Acacia nilotica, Acacia reficiens, Terminalia prunioides, Commiphora multijuga and Combretum apiculatum. Blocking of surface and/or groundwater flow will result in loss of perennial species and a reduction in the resources, such as food, shelter and soil stabilisation for burrows that they represent to other trophic groups. Washes and drainages play the same important role in arid zones as rivers and are considered very sensitive. Development that is planned in this habitat includes linear structures such as roads, pipeline and power line.

6.6.3.3 Mopane Scrubland Open Mopane woodland covers the largest part of ML40. The topography of this habitat is gently undulating, bisected by ridges topped with rocky outcrops and drainages. In the east and southeast of the study area, the topographic profile is flatter with fewer and lower rocky ridges than in the west and northwest, where there are more and steeper rocky ridges. The substrate consists of loose stones and gravel on compacked sand. The vegetation structure varies slightly from west to east, broadly corresponding to changes in topography with larger Mopane trees and some Commiphora species in the western parts of the study area. In the east and southeast Colophospermum mopane form a scrubby open woodland of homogenous height and structure, interspersed with Catophractes alexandri. Mopane trees are interspersed with Terminalia prunioides, Boscia microphylla, Commiphora multijuga and other Commiphora species, as well as Ceraria pedunculata. The understorey is sparse, and grass was the only ground cover observable at the end of winter, but more annual plant species are expected to appear after rain. The low density and diversity of plant species, combined with the relative homogeneity of this habitat, result in a relatively low ecological value for vertebrates. This habitat has been modified by human activities such as harvesting and livestock grazing. Both these activities are current and ongoing, and the village Oroutumba is in a degraded area in Mopane woodland abutting the Ondoto River. Roads and accessory works will be in this habitat. It is considered the least sensitive habitat, but care should be taken to maintain the natural flow patterns of surface water in all drainage lines.

6.6.3.4 Species description The taxa that were investigated are listed in the Appendix I. Species were included in the lists if they: ➢ are expected to occur or have been previously recorded in the study area, and ➢ are compatible with the habitats in the study area Species that are range-restricted endemics, have Threatened status, or which are legally protected in Namibia, are potentially of concern.

6.6.3.4.1 Mammals An estimated 85 species of mammals have distribution ranges that overlap with the study area and 64 of these are expected to be found in the habitat types in the study area. This is a relatively high species richness but the habitat characteristics on the site are limiting for mammal density. In addition,

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021 disturbance caused by farming and harvesting has contributed to low densities of large mammals and no signs of large mammals were observed during the site visit. The Damara Rock Squirrel and Pygmy Rock Mouse are Namibian endemics that are highly likely to occur in the study area. Of the 64 species for which habitat suitability is high or medium, five are listed in the IUCN’s Vulnerable or Near-threatened categories and nine are Vulnerable, Rare or Near- threatened in Namibia (pangolin, aardwolf, brown hyena, cape grey mongoose, Damara woolly bat, elephant, African wild cat, bat-eared fox and Cape fox). Bat-eared fox, Cape fox, aardwolf and brown hyena are particularly vulnerable to death by vehicle collision, exacerbated by increased traffic on the D3701. D3700 could be alternative route and travelling by day will mitigate this risk.

6.6.3.4.2 Birds The Southern African Bird Atlas Project 2 (SABAP2, 2020) records 254 species in the region, and the habitats of the study area are highly suitable for 187. This is a high species richness for such an arid environment, representing 37% of the 687 species recorded for Namibia (Simmons, et al., 2015). Eight of the expected species are threatened in Namibia, including the Martial Eagle and Tawny Eagle that are also globally threatened. The other six species are Angola Cave-chat (near threatened), Verreaux’s Eagle (near threatened), Yellow-bellied Eremomela (endangered), Rüppel’s Parrot (near threatened), Wood Sandpiper (vulnerable) and Cinderella Waxbill (endangered). Carp’s Tit, Hartlaub’s Spurfowl, White-tailed Shrike, Rüppel’s Parrot, Damara Hornbill, Monteiro’s Hornbill and Bare- cheeked Babbler are near-endemic to Namibia, defined as more than 90% of the world population occurring in the country. Raptors, bustards and all migrating species are vulnerable in varying degrees to impacts caused by power lines, e.g. collision, electrocution, disturbance and habitat destruction. The location of the power line to service the accessory works area was not finalised at the time of writing, preventing a thorough assessment of this impact. This is addressed in the recommendations in chapter 4 of the fauna report.

6.6.3.4.3 Reptiles The study area is located in a high diversity zone for reptiles, ranked second-highest in Namibia by Mendelssohn et al, 2002 and the distribution ranges of 66 reptile species overlap with the project site , with habitat suitability considered high or medium for 56 of these species. Only one of the 56 species, Hellmich’s Wolf Snake, is on the IUCN list where it is categorised as Data Deficient. Nationally it is considered Rare. In addition, seven other species are considered Vulnerable, Rare or Endangered in Namibia. It is important to note that 19 species are endemic (100% of breeding population in Namibia) or near-endemic (>75% of breeding population in Namibia), representing 34% of the potentially occurring reptile species in the area and making the project site an area of high concern for reptiles. The national and international assessment of this taxon is almost 15 years old and it is likely that the situation, specifically regarding threatened species, has changed significantly.

6.6.3.4.4 Amphibians Distribution ranges (Du Preez & Carruthers, 2009) indicate that 20 frog species could potentially occur here and 17 of these species have a medium or high probability of being found on the project site. This is a much higher species richness than the ranking Mendelssohn et al (2002) gives for the region due to data that became available after 2002. The Kunene River and its riparian vegetation contribute to the unexpectedly high potential diversity of amphibians in this arid area. The Damara Pygmy Toad is endemic and the Marbled Rubber Frog near-endemic to Namibia. A third species of conservation concern is the Giant Bullfrog: near threatened in Namibia and numbers decreasing globally.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

The Ondoto River had water in the middle of winter at the point where it intersects ML40, leading to the assumption that standing or slow-moving water is present year-round, providing habitats that may be suitable for the expected species. This increases the likelihood of the study area supporting more frog species than would be expected in such a low rainfall area. It is essential for frog diversity to keep washes and drainages unobstructed and to maintain the natural runoff patterns of water from the hills to the Ondoto River.

6.6.3.5 Impact assessment and summary The fauna specialist identified the following 7 key potential impacts: ➢ Potential destruction of organisms and habitats ➢ Potential disturbance of animals and interference with their behaviour ➢ Light pollution ➢ Alteration of topography ➢ Groundwater drawndown ➢ Contamination o soild and water ➢ Impacts linked to accommodation of staff Three of these were rated as having medium unmitigated significance, all three declining to low significance with the implementation of mitigation and management measures. Impact one, the direct destruction of organisms and habitat, has a high unmitigated significance, but the application of a restoration plan and strict implementation of management measures mitigate it to a low significance. The significance of impacts on birds and mammals is limited to some extent by the low densities at which these taxa occur in the area. The alteration of topography by quarries and waste heaps, may not be mitigated to any meaningful level. Nevertheless, the significance of the impact drops to low, provided an effective restoration plan is budgeted for and implemented appropriately and efficiently. It is important to keep the project footprint to the absolute smallest size possible, and to keep it inside well-defined and clearly demarcated boundaries by fencing the operational area and putting up visible and effective signs. The purpose of a fence and signs is to inform personnel and contractors of the exact boundaries of the operations area and to effectively control access to areas that will remain undeveloped. Fences and signage go hand in hand with appropriate environmental training, raising awareness of staff, and contractors and their staff. The riverine habitat has a high ecological value for all taxa, plays a keystone role in nutrient transport, and serves as important source areas for recolonisation. In the project footprint, the two rivers and large eastern ravine are considered very sensitive and apart from the proposed linear infrastructure, no development should take place there. In addition, the natural flow patterns in washes, ravines and other drainage lines should be maintained. A restoration plan, if implemented efficiently, could potentially contribute positively to conservation. The protection of source areas from where seeds and organisms will come to re-colonise the disturbed areas is a crucial aspect of restoration. For a restoration programme to be effective, it is essential that it be implemented from the earliest possible time after the construction phase of the project, and throughout the operational phase where possible, so as to ensure that source areas are identified and protected from the beginning. Restoration should, where possible, not be left until the end of mining.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

6.7 SOCIO-CULTURAL ENVIRONMENT

6.7.1 Introduction Ashby (2019) quotes the Kunene Regional Council’s Development Profile of 2015 in stating that it supports mining of mineral resources as it will contribute to economic growth of the region. More specifically, it suggests that investors within the mining sector are encouraged to engage in Public Private Partnerships (PPPs) with local communities, thereby addressing the inequitable distribution of mineral resources in the region.

6.7.2 Demography According to the Namibian Statistics Agency reporting of 2013 and 2014 (Ashby 2019) between 2001 and 2011, the regional population grew at an annual rate of 2.3% which is faster than the national average of 1.4%. The population lived in 18,500 households, with an average household size of 4.6 persons. The Epupa Constituency had a population of over 17,000 inhabitants while the town of Opuwo’s population was 7,657. The devastating drought years since 2013 have caused many farmers to lose their livelihoods and have increased migration to Opuwo to be in easier reach of drought-relief food from the government (Ashby 2019). This has put considerable strain on the Opuwo Town Council to provide basic services such as water, ablution and refuse removal in the informal settlements which have expanded rapidly. This has little bearing on the mine operations itself but provides an indication of the current pressures experienced by the authorities to meet the needs of the people in the region.

6.7.3 Regional Economics According to the National Planning Commission 2015 reporting (Ashby 2019) the Kunene Region has the second highest proportion of people classified as materially deprived (63.4% compared to the national average of 48%), reflecting the relatively high proportion of semi-nomadic pastoralist Himba people in the region with few material possessions. According to the 2014 national statistics data summarised by Ashby (2019) 84% of people in the Kunene Region live in inadequate housing conditions which lack basic services to the home, compared to the national average of 76%. In the Epupa Constituency, only 29% of households had access to safe water and 92% of households had no toilet facility. Only 8% of households used electricity for lighting and 92% had no decent lighting (critical for improving school performance). Approximately 78% of households in this area relied on wood or charcoal for cooking.

6.7.4 Education According to the 2015 Planning Commission (Ashby 2019), the region has the highest levels of education deprivation of all the regions (81.6% compared to the national average of 63%), measured by educational attainment reached by people aged 15 to 59 inclusive.

6.7.5 Land Use Agriculture is the most important employment sector in the region but as the region is very arid, farming was the main source of income for only 31% of households in 2011 (Ashby 2019). In theory communal grazing of livestock benefits from rangeland management practises which protect and enhance the grazing resource. This fits very well with Namibia’s Community Based Resource Management programme of conservancies which has enabled communities to manage the natural resources in their areas and use them for community benefits and improvement of individual livelihoods. The high number of conservancies and community forests in northern Kunene is largely a reflection of the remoteness of many areas and the divisions within communities, often along ethnic lines. The mine site falls within the border of a conservancy, namely Kunene River Conservancy. Figure 33 renders a map of the conservancy relative to the project area. In principle the community gain

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021 benefits from the conservation of the biodiversity through eco-tourism and potential hunting tourists during permitted periods of the year. It is not expected that the mine will have a direct impact on these conservancy endeavours.

Figure 33. Map showing the extent of the Kunene River Conservancy Other small scale mining takes place in the area and KNL has been instrumental in assisting these small operations. The small-scale miners (SSM) may mine on pre-approved areas within ML40 and the MCs. The following modus operandi was implemented last year by KNL to accommodate and improve the sales and marketing of sodalite: 4) All high quality “super” sodalite is bought on site from the SSM daily. 5) The B1 and 70/30 sodalite qualities are sold by the SSM to Namibian, South African and Chinese customers and KNL oversees the administration and the fairness of these transactions. 6) KNL assists the SSM by constructing their mining sites and commence their activities. KNL currently supports 10 pre-approved groups consisting of both, women and men. Each group consists of between 5 to 10 self-employed miners. Current total is 65 self-employed miners. According to the National Planning Commission, the Epupa Constituency is famous for its Ovahimba pastoralists, and 83% of households in the constituency are involved in livestock farming and many settlements have grown up around natural springs and 65% of the constituency’s household’s practised crop farming as documented during the 2011 census (Ashby 2019). According to national statisitics reporting of 2014 (Ashby 2019) the reliance on agriculture as the main source of income to 78% of households in the constituency highlights their vulnerability to drought. The Kunene Regional Development Profile Report states that the percentage of households receiving an income from pensions is 8% and from wages and salaries is 6%, the rest it is assumed mainly from agriculture (Ashby 2019).

6.7.6 Residence Survey A baseline residence survey of the surrounding area was carried out in the first two weeks of August 2020. The raw data collected during the survey is available on request. It is not published in this report

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021 for confidentiality reasons. During the survey, many dwellings up to 5km away from the ML40 boundary were surveyed.

Figure 34 renders a map of the locations of the residence that were surveyed. A member of each dwelling completed a questionnaire to document information about the families staying there. Intermittant residency of the some of the residences was confirmed by the survey. Near the planned new processing plant 3 clusters (homestead) of residences were surveyed. Figure 35 below renders a map showing these nearby residences. The results of the survey for these residences is given in Table 15 below. 26 people live in these residences permanently. Should the processing plant, waste rock dumps or tailings facility create conditions that are potentially dangerous for residents who will live permanently less than a kilometre from these sources, then the proponent will need to consider some form of compensation in whatever form is required.

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Figure 34. Locations of the potential homesteads surveyed relative to the mineral licences.

Figure 35. Dwellings near the New Processing Plant

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Table 15. Residence survey data (waypoints correspond with Figure 35 above) ID Latitude Longitude y - Projection x - Projection Total Persons Age/Gender P1 Age/Gender P2 Age/Gender P3 Age/Gender P4 Age/Gender P5 Age/Gender P6 0.40 -17.35594338 13.77579306 8080653.484 369931.7439 1 19F 0.41 -17.35586903 13.77614519 8080661.949 369969.1082 6 64F 15M 13M 10F 7F 5M 0.72 -17.35770416 13.78034377 8080461.73 370416.5401 2 19 7F 0.73 -17.35780399 13.78039129 8080450.716 370421.6603 5 40F 15F 4M 3M 2F 0.74 -17.35789469 13.78048634 8080440.745 370431.8241 2 22 8 0.75 -17.35789921 13.78059573 8080440.318 370443.4502 3 65F 4M 4F 0.76 -17.35777675 13.7808191 8080454.019 370467.1001 abandoned 0.77 -17.35759528 13.78084291 8080474.114 370469.5021 1 19 0.78 -17.35982931 13.77485815 8080222.872 369835.1426 1 34 0.79 -17.3596206 13.77520985 8080246.204 369872.3668 storeroom 0.80 -17.3595662 13.77487709 8080251.998 369836.9696 2 70M 11F 22M 0.81 -17.35610892 13.77574227 8080635.132 369926.4632 3 12F 8M 7M 0.82 -17.35615427 13.7759514 8080630.256 369948.7172 unknown 6.7.7 Infrastructure and Services The following infrastructure existed prior to starting this environmental scoping with assessment: ➢ Mining offices and storage buildings ➢ Diesel generators and internal powerlines for quarry equipment, offices and other mine buildings ➢ Pump and water pipeline (using water from the hand dug well in the Ondoto river) ➢ Access roads Exploration tracks traverse the ML40 area which have existed for decades. Larger tracks access the the quarries from the south and northNampower and Northern Electricity Distributor currently have electrical infrastructure supplying the Otjimuhaka (previously Swartboois Drift) settlement some 7km from the main quarry site. No electricity lines convey electricity to the mining area. It is assumed that the sewerage facilities for the residences at Oroutumba consist of French drains.

6.7.8 Cultural Heritage Although the people themselves represent a rich and important heritage in terms of the lifestyle, traditions and ongoing cultural practices, the ML40 and the 6 Mining Claims are not located in an area where documented sensitive sites are found. A meeting and site visit with the local leaders confirmed the location of important graves and ritual sites. No important pre-historic sites are known to exist in the areas to be mined and developed. See Appendix N for the short report on the outcome of the heritage site visit and meeting. Figure 36 renders a map of the sites that traditional leaders and the educational cultural officer visited to see if there were any heritage sites of importance. The survey report was submitted to the National Heritage Council of Namibia with an application for an EIA Consent Application. The receipt for this application is found in Appendix N.

6.7.9 Potential Impacts This medium scale mining project will bring a number opportunities for employment during construction and operations. It will have a small positive socio-economic impact both in the immediate project area and at the nearest larger towns of Opuwo and Ruacana. Potential impacts which will be assessed in include: ➢ Economic impact at national, regional and local levels ➢ Jobs and skills development ➢ Minor negative livelihood changes in the immediate project area: e.g. loss of grazing, possible relocation of one or more households. ➢ Benefits to livelihoods in the immediate project area: e.g. improved infrastructure such as road and potential for local SMEs such as a shop or security company. ➢ Positive and negative impacts on Otjimuhaka, Opuwo and Ruacana: infrastructure and services developments e.g. housing and service industries. ➢ Negative impacts of in-migration e.g. unsuccessful jobseekers, sexually transmitted diseases

100

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

No fatal flaws have been identified for the envisaged project development and operations.

Figure 36. Site locations of the heritage survey.

101

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

102

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

7 IMPACT ASSESSMENT The impact assessment of all the listed aspects was carried out using an adaptation of the Hacking Method. Both, the criteria used to assess the impacts and the Method of determining the significance of the impacts, is outlined in Table 16 below: (This procedure complies with the method provided in the Namibian EIA Policy document and EIA regulations) ➢ Part A provides the approach for determining impact consequence (combining severity, spatial scale and duration) and impact significance (the overall rating of the impact). ➢ Impact consequence and significance are determined from Part B and C. ➢ The interpretation of the impact significance is given in Part D. Both mitigated and unmitigated scenarios are considered for each impact. The purpose of this section is to assess and identify the most relevant environmental impacts by describing certain quantifiable aspects of these and to provide possible mitigation measures to minimise the magnitude of the impacts that would be expected from the gravel mining activities. The following potential impacts on the environment for the mining activities were identified and assessed: ➢ Air quality ➢ Noise ➢ Health & safety ➢ Visual ➢ Land use ➢ Waste ➢ Ecological &Biodiversity ➢ Water Resource ➢ Socio-economic ➢ Traffic ➢ Product Handling & Port Storage ➢ Heritage ➢ Post Mining Legacy These identified potential impacts were evaluated. A mitigation hierarchy was considered as follows. Firstly, one tries to prevent the impact. If this is not possible then mitigation measures are applied to each aspect. Should the mitigation measures not reduce the impact, then an alternative site or method is considered. If an alternative is not possible then rehabilitation is considered as the last onsite resort. Usually, a combination of mitigation measures, alternative methods and rehabilitation is carried out to lower the impacts. If none of the above can be achieved to reduce the impact in the long term, then an offset can be considered where an improvement to the environment at another project site is actioned or a considerable contribution is given to a biodiversity conservation cause elsewhere is made.

Table 17 to Table 32 describe and assess the potential impacts of the project.

103

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Table 16. Criteria for assessing impacts PART A: DEFINITION AND CRITERIA Definition of SIGNIFICANCE Significance = consequence x probability Definition of CONSEQUENCE Consequence is a function of severity, spatial extent and duration Criteria for ranking of the H Substantial deterioration (death, illness or injury). Recommended level will often be SEVERITY/NATURE of violated. Vigorous community action. Irreplaceable loss of resources. environmental impacts M Moderate/ measurable deterioration (discomfort). Recommended level will occasionally be violated. Widespread complaints. Noticeable loss of resources. L Minor deterioration (nuisance or minor deterioration). Change not measurable/ will remain in the current range. Recommended level will never be violated. Sporadic complaints. Limited loss of resources. L+ Minor improvement. Change not measurable/ will remain in the current range. Recommended level will never be violated. Sporadic complaints. M+ Moderate improvement. Will be within or better than the recommended level. No observed reaction. H+ Substantial improvement. Will be within or better than the recommended level. Favourable publicity. Criteria for ranking the L Quickly reversible. Less than the project life. Short term DURATION of impacts M Reversible over time. Life of the project. Medium term H Permanent. Beyond closure. Long term. Criteria for ranking the L Localised - Within the site boundary. SPATIAL SCALE of impacts M Fairly widespread – Beyond the site boundary. Local H Widespread – Far beyond site boundary. Regional/ national

PART B: DETERMINING CONSEQUENCE SEVERITY = L DURATION Long term H Medium Medium Medium Medium term M Low Low Medium Short term L Low Low Medium SEVERITY = M DURATION Long term H Medium High High Medium term M Medium Medium High Short term L Low Medium Medium SEVERITY = H DURATION Long term H High High High Medium term M Medium Medium High Short term L Medium Medium High L M H Localised Fairly widespread Widespread Within site boundary Beyond site Far beyond site Site boundary boundary Local Regional/ national SPATIAL SCALE

PART C: DETERMINING SIGNIFICANCE PROBABILITY Definite/ Continuous H Medium Medium High (of exposure to Possible/ frequent M Medium Medium High impacts) Unlikely/ seldom L Low Low Medium L M H CONSEQUENCE

PART D: INTERPRETATION OF SIGNIFICANCE Significance Decision guideline High It would influence the decision regardless of any possible mitigation. Medium It should have an influence on the decision unless it is mitigated. Low It will not have an influence on the decision.

*H = high, M= medium and L= low and + denotes a positive impact.

104

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Table 17. Air Quality Impacts Impact Event Disturbances to soil, rock and ore resulting in excessive dust in the atmosphere Description Dusty atmospheric conditions do prevail in the arid north west of Namibia particularly during the winter months when dry easterly winds blow and during early summer months and when south westerly winds blow. Mining activities will generate dust as follows: ➢ Movement of vehicles along road network hauling ore to the plant on site are likely to lift dust into the air ➢ Trucks transporting product along the dirt roads travelling south through to Henties Bay after which the road surface is bitumen tar. ➢ Drilling and blasting will most definitely cause dusty conditions. ➢ Crusher, sifting screens and conveyor functioning will result in dusty conditions. ➢ The TSF and waste rock dump (WRD). ➢ Product handling & storage areas The surrounding habitats receive the dust that emanates from the mining activiites and may potentially be affected. Fauna and flora alike could be impacted as ecosystem functioning is possibly affected. Negative effects of dust on personnel working at the quarry site are likely to occur if dust suppression techniques are not employed and personal protection equipment is not used to safeguard the health of personnel. It is not known how many people lived at Oroutumba before the existing sodalite quarry work started decades ago but currently there are at least 50 residences within 500m of the main quarry site. At the planned new processing site there are only 26 people living in 10 residences at 250m to 750m away from the boundary of the new accessory works area. Nearby residents may be affected by these dust sources. Nature Negative Phases during which sources of dust apply are highlighted below; Significance assessment was Phases carried out on the operational phase which presents a long term risk. Construction Phase Operational Phase Decommissioning Phase Post Closure Dismantling crushers & Crushers & screens Crushers & screens screens Conveyor construction Conveyor functioning Dismantling conveyors Road network Background levels will most Road use and maintenance Demolishing buildings establishment likely resume soon after closure. Building construction Drilling & blasting Rehabilitation of slopes Ore haulage from quarry pit Constructing fences Product handling & storage Moderate / measurable deterioration (discomfort). Recommended level will occasionally be Severity violated. Duration Reversible over time. Life of the project. Medium term Fairly widespread – Beyond the site boundary. Localised at best. Though this does depend on mobility of particles and prevailing weather conditions. The only place outside the local area is Spatial Scale along the gravel road between the mine and Opuwo or Ruacana and then again between Kamanjab and Henties Bay via Khorixas. Probability Definite and continuous Mitigation Severity Duration Spatial Scale Consequence Probability of Occurrence Significance Unmitigated M M M M H M Unless it is mitigated the generation of dust should have an influence on the decision to carry Significance of out the activity or not. Natural weather conditions can create very dusty atmospheric Consequence conditions regardless of the existence of the mine. However, mining and processing activities on site will contribute significantly to local atmospheric dust levels and could potentially affect

105

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

the ecosystem functioning. Company personnel could be affected depending on the content of the atmospheric dust and how great the exposure is. Dust creation cannot be prevented completely. Water is normally used to suppress dust on the Prevention roads. However, this scarce resource cannot be applied continuously and indiscriminately without impacting the groundwater resource. Dust suppression techniques will be necessary when dust becomes an issue during the dry winter months. The following can be done to reduce exposure of the environment and personnel to continuous and excessive dust plumes: ➢ Avoid dust generating activities that create excessive dust during windy conditions. ➢ The new and refurbished roads should have a hard surface whose integrity will not be easily compromised. ➢ Personnel are required to wear personal protection equipment if excessive dust should be created. ➢ All vehicles transporting product material off site should be covered with a tarpaulin when travelling on the national road network of tar and gravel roads. ➢ Windbreaks and covers can be used to reduce lifting of dust from crushers, screens and conveyors. ➢ Water spays at the various plant components will effectively keep dust from blowing into Mitigation Action the atmosphere (only if water sources are sustainably used) ➢ The road network within the mine site can be sprayed with water and other dust suppressants during dry dusty conditions (only if water sources are sustainably used) ➢ Waste rock dumps (WRDs) and the TSF should be landscaped and compacted where necessary to supress erosion of soil and dust emission on windy days. ➢ Natural revegetation of the WRDs and the TSF side walls would mitigate the amount of dust that these sources could generate. ➢ To mitigate gaseous pollutants released from the combustion of hydrocarbons, use of high-quality fuels will ensure quantities released per unit weight of product are at levels within environmental limits. ➢ In order to know whether the dusty conditions created by mining activities will exceed the limits or standards set for the southern African context it is necessary to set up a monitoring network of dust fallout buckets. The results of the monitoring will confirm the ambient air quality during baseline pre-construction conditions, and this will provide a gauge by which the site-specific conditions compare to the industry standards used. Mitigation Severity Duration Spatial Scale Consequence Probability of Occurrence Significance Mitigated L L M L L L Significance of The dust suppression techniques if applied diligently and consistently will result in a low Consequence significance impact for both the biophysical and social environment. High, provided management implements the mitigation action and the company provides the Confidence Level necessary financial support to implement the measures required Table 18. Noise Impacts Impact Event Disturbance of sense of place and the effect on tranquil ambient noise levels Description Potential noise sources during the mining and processing activities could originate from vehicles, earthmoving equipment like excavators and graders, generators, drilling and blasting, crushers, screens, and conveyors. The irritation issue of these noise sources will depend on the closeness of the mining activities to various receptors. The nearest residences are between 250m and 2km from any mining activity. It is not known how many people lived at Oroutumba before the existing sodalite quarry work started decades ago but currently there are at least 50 residences within 500m of the main quarry site. At the planned new processing site there are 26 people living in 10 residences from a250m to 750m away from the boundary of the new accessory works area. For rural districts the day-time ambient noise level requirement outlined in SANS 10103 (2008) between 6am and 10pm is 45dBA (A-weighted decibel). This is in line with the guidelines published by the World Health Organisation (WHO). The noise levels should not exceed the ambient noise levels for rural settings. The residences mentioned above would fall into the rural category.

106

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Nature Negative Phases during which sources of noise will apply are highlighted below; Significance assessment Phases was carried out on the operational phase which presents a long-term risk. Construction Phase Operational Phase Decommissioning Phase Post Closure Rock Cutters, crushers & Dismantling crushers & Crushers & screens screens screens Conveyor construction Conveyor functioning Dismantling conveyors Background or baseline levels will most likely become Vehicles on road network Vehicles on road network Demolishing buildings prevalent again immediately after closure. Building construction Drilling & blasting Rehabilitation of slopes Ore haulage from quarry pit Constructing fences Moderate / measurable deterioration (discomfort). Recommended level will occasionally be Severity violated. Widespread complaints. Noticeable loss of resources. Duration Reversible over time. Life of the project. Medium term Fairly widespread – Beyond the site boundary. Localised at best. Though this does depend on Spatial Scale prevailing wind conditions proximity of residents. Probability Definite and continuous Mitigation Severity Duration Spatial Scale Consequence Probability of Occurrence Significance Unmitigated M M M M H M Significance of Mitigations to reduce noise levels measured at receptors will be necessary. Consequence Noise creation cannot be prevented and will occur and should be mitigated. Additional traffic Prevention planned for the road for hauling product cannot be avoided. There are industrial standards to which the noise sources (i.e. machinery) must comply. Regular maintenance of machinery should ensure the acceptable noise levels for operators working with the machines. It is not clear whether this will produce the accepted rural standard at the homesteads. It is recommended that any complaints regarding noise be recorded and included in the environmental reports. Should complaints persist then a survey by a suitably qualified and independent occupational hygienist will be required. Mitigation Action Shields which deflect the noise away from receptors may reduce the decibels to within the rural standards. The placement of stockpiles and buildings will also play a role to ensure sources of noise are not directly in line with the farm homestead. Transportation routes should be planned for trucks such that they pass noise sensitive receivers at appropriate times. A restriction of the hours of movement, e.g. not allowing the transport of material during the noise sensitive hours of the night can mitigate noise impacts. The frequency (distance between trucks can also be planned to fall within a limited period. Mitigation Severity Duration Spatial Scale Consequence Probability of Occurrence Significance Mitigated L M M L L L The normal maintenance may reduce the probability of noise marginally. Should the shielding Significance of of noise sources keep the noise measured at the receptors to within the limits then the Consequence significance could drop to low. The EAP is confident that the mitigations will result in the impact significance. A good Confidence Level monitoring system will enable the mine to document the facts and respond accordingly by enhancing any noise reduction strategies. Table 19. Health & Safety Impacts – Noise and Vibration Effects on Personnel Impact Event The effects of excessive noise and vibration on the health and safety of personnel. Description Noise:

107

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

➢ Long term exposure to high levels of noise can cause permanent hearing loss. Neither surgery nor a hearing aid can help correct this type of hearing loss. ➢ Short term exposure to loud noise can also cause a temporary change in hearing (your ears may feel stuffed-up) or ringing in your ears (tinnitus). These short-term problems may go away within a few minutes or hours after leaving the noisy area. Vibration: Different vibration types are defined as: ➢ Hand-Arm Vibration is defined as mechanical vibration that, when transmitted to the human hand-arm system, entails risks to the health and safety of workers, vascular, bone or joint, neurological or muscular disorders. Whole-Body Vibration is defined as the mechanical vibration that, when transmitted to the whole body, entails risks to the health and safety of workers lower back morbidity and trauma to the spine. Nature Negative Phases during which sources of noise and vibration could apply are highlighted below; Phases Significance assessment was carried out on the operational phase which presents a long-term risk. Construction Phase Operational Phase Decommissioning Phase Post Closure Rock Cutters, Crushers & Dismantling crushers & Crushers & screens screens screens Background or baseline levels Conveyor construction Conveyor functioning Dismantling conveyors will most likely become prevalent again immediately Vehicles on road network Vehicles on road network Demolishing buildings after closure. Personnel no Building construction Drilling & blasting Rehabilitation of slopes longer on site. Ore haulage from quarry pit Constructing fences Substantial deterioration (permanent damage to spine from vibration or hearing). Severity Recommended level will often be violated. Personnel potentially unable to work any longer. Duration Permanent. Beyond closure. Long term. Spatial Scale Localised - Within the site boundary. Probability Definite and continuous Mitigation Severity Duration Spatial Scale Consequence Probability of Occurrence Significance Unmitigated M M L M M M Significance of Mitigations to reduce noise levels and exposure to vibrations for personnel are imperative. Consequence Engineering controls that reduce sound exposure levels are available and technologically feasible for most noise sources. Engineering controls involve modifying or replacing equipment, or making related physical changes at the noise source or along the transmission path to reduce the noise level at the worker's ear. The same goes for vibration. The following Prevention should be considered: ➢ Choose low-noise tools and machinery. ➢ Maintain and lubricate machinery and equipment (e.g. oil bearings). ➢ Enclose or isolate the noise source. Noise: The Occupational Safety and Health Administration (OSHA) guidelines set legal limits on noise exposure in the workplace. These limits are based on a worker's time weighted average over Mitigation Action an 8 hour day. With noise, OSHA's permissible exposure limit (PEL) is 90dBA for all workers for an 8 hour day. The OSHA standard uses a 5dBA exchange rate. This means that when the noise level is increased by 5dBA, the amount of time a person can be exposed to a certain noise level to receive the same dose is cut in half.

108

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

The WHO guideline on maximum noise levels to prevent hearing impairment set noise level limits at an average of 70 da over a 24-hour period with maximum noise levels not exceeding 110 dBA during the period. These limits would apply if the day-time shift is prolonged beyond the 8-hour day. Mitigation actions include: ➢ Operating noisy machines during shifts when fewer people are exposed. ➢ Limiting the amount of time, a person spends at a noise source. ➢ Providing quiet areas where workers can gain relief from noise sources. ➢ Where possible, restricting worker presence to a suitable distance away from noisy equipment. (Controlling noise exposure through distance is often an effective, yet simple and inexpensive administrative control.) ➢ In open space, the further the distance from the source of noise, the worker may experience a decrease in noise levels to be about 6dBA less for every doubling of the distance (nonlinear relationship). ➢ Hearing protection devices, specifically earmuffs for long periods of exposure near sources and at all times use plugs for all places outside offices within the claims not near noise sources for extended periods ➢ PPE is considered an acceptable mitigation, but a less desirable option to control exposures to noise. ➢ Entrance and exit medicals to test hearing should be carried out as a minimum requirement. Vibration: Meet industry vibration regulations; set daily exposure limit values and action values for both hand-arm and whole-body vibration for eight-hour shifts. Personnel can work shorter shifts where excessive vibration conditions exist. Mitigation Severity Duration Spatial Scale Consequence Probability of Occurrence Significance Mitigated L M L L L L Significance of If all the mitigations listed are used then the significance of the impact will be maintained at Consequence low. The EAP is confident that the mitigations will result in low significance. A good monitoring Confidence Level system will enable the mine to document the facts and respond accordingly by enhancing any noise and vibration reduction strategies. Continuous training of personnel is imperative Table 20. Health & Safety Impacts – General Hazards and Potential Risk of Injury Impact Event Injury risks due to normal working conditions Description The potential impacts on human health and safety resulting from activities in any phase could include occupational accidents and injuries, vehicle accidents, exposure to weather extremes, trips and fall on uneven terrain, adverse health effects from dust generation and emissions, and contact with hazardous materials. The potential for these impacts to occur would be low because of the limited range of activities and number of workers required during operations. Gecko follows a set of industry-specific safety and health policies in the work place. Typical operational procedures that pose risks to operational personnel are: ➢ Operating heavy machinery such as, front-end loaders, excavators, and stationary processing equipment. ➢ Operating haulage trucks Nature Negative Phases and specific activities or equipment during which personnel are exposed to health and Phases safety risks will apply are highlighted below; Significance assessment was carried out on the operational phase which presents a long term exposure risk. Construction Phase Operational Phase Decommissioning Phase Post Closure

109

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Processing plant Processing plant operations Dismantling processing plant construction site Rock falls from steep and Rock falls from steep and Rehabilitation of slopes high cliff faces of quarry pit high cliff faces of quarry pit Personnel no longer on site. Public safety ensured Large mobile plant Large mobile plant through restricted access equipment and product Demolishing buildings equipment though quarry pit will remain. haulage Working at heights Drilling & blasting Constructing fences Fire and explosion hazards Substantial deterioration. Should industry standards be exceeded personnel may potentially Severity be unable to work any longer. Duration Permanent. Beyond closure. Long term. Spatial Scale Localised - Within the site boundary. Probability Definite and continuous Mitigation Severity Duration Spatial Scale Consequence Probability of Occurrence Significance Unmitigated H H L H H H Significance of Mitigations to reduce exposure to health and safety risks for personnel are imperative. Consequence The removal of hazards or risks will possibly prevent accidents from occurring. However, it is Prevention not possible to remove all risks. It is not possible to prevent all incidents from occurring completely. An accident is an unplanned incident though it could have been foreseen if the necessary precautions had been taken. Not all hazards can be removed but the risk it presents can be lowered. An integrated health and safety management system acts as a monitoring tool and mitigating tool to reduce the risks. Typical mitigating measures within the health and safety management systems are:- ➢ Draw up operational procedure manuals ➢ Provide health and safety awareness training ➢ Establish practical standard housekeeping rules ➢ Colour code certain areas, equipment and substances to thereby classifying the risks. ➢ Provide signage for personal protective equipment (e.g. protective clothing like safety boots and hard hats) ➢ Institute safe working procedures and require permits to work Mitigation Action ➢ Devise and implement emergency response plans ➢ Close coordination with the traffic authorities to ensure road safety signs are strategically placed and ensure all employee drivers are well trained ➢ Provide easy access to Material Safety Data Sheets (MSDS) ➢ Provide first aid treatment and training ➢ Devise emergency medical procedures for all eventualities ➢ Undertake daily safety reminders and/or drills ➢ Establish regulations for handling fuel The MSDS gives health related medical responses for personnel assisting staff who are exposed to the fuels. Procedures for dealing with injuries or accidents must be in place and all contact details for emergency personnel must be available.

110

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

This list is not comprehensive and could be supplemented substantially by the Health & Safety Manager Mitigation Severity Duration Spatial Scale Consequence Probability of Occurrence Significance Mitigated L L L L L L Significance of If all the mitigations listed are implemented then the significance will be maintained at low. Consequence The EAP is quite confident that the mitigations will result in low significance. Continuous Confidence Level training of personnel is imperative. Table 21. Health Impact due to exposure to radioactive particulates and normal working conditions. Impact Event Disease or normal health risk due to normal working conditions and in particular to exposure to radioactive particulates Description The potential impacts on human health and safety resulting from activities in any phase could include occupational accidents and injuries, vehicle accidents, exposure to weather extremes, trips and fall on uneven terrain, adverse health effects from dust generation and emissions, and contact with hazardous materials. The potential for these impacts to occur would be low because of the limited range of activities and number of workers required during operations. The proponent and his operational mining company follows a set of industry-specific safety and health policies in the workplace. Typical operational procedures that pose risks to operational personnel are: ➢ Operating heavy machinery such as, front-end loaders, excavators, conveyors, crushers and sieves ➢ Operating haulage trucks ➢ Prolonged proximity to and exposure to manganese particulates The REE ore and REE product concentrate is potentially hazardous because of the radioactive nature of the thorium at higher concentrations. Through the processing of the REE ore the thorium element is expected to concentrate and as a result increase the risk of radioactive emissions. Working at the mine’s quarries and processing plant could increase the exposure to this risk. The risks associated with exposure to radioactive materials is increased by three factors. Namely, the proximity to the source, the period of time spent on any one occasion near to the source and thirdly the frequency with which you are exposed over a long period of time. These factors affect the potential with which the radiation can cause sickness and or death. Radioactive exposure can be through inhalation, oral, dermal contact or close to the source without contact. The effects can be carcinogenic in nature and can eventually lead to death. Nature Negative Phases and specific activities or equipment during which personnel are exposed to health and Phases safety risks will apply are highlighted below; Significance assessment was carried out on the operational phase which represents the period personnel are exposed to the hazard. Construction Phase Operational Phase Decommissioning Phase Post Closure Processing plant operations, Dismantling processing plant Processing plant product storage and and handling ‘radioactive construction site handling, and transport of contaminated materials’ concentrate Rock falls from steep and Rock falls from steep and Rehabilitation of slopes Personnel no longer on site. high cliff faces of quarry pit high cliff faces of quarry pit Public safety ensured through restricted access Large mobile plant Large mobile plant though quarry pit will remain. equipment and product Demolishing buildings equipment haulage Working at heights Drilling & blasting Constructing fences Fire and explosion hazards

111

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Substantial deterioration. Recommended level will often be violated. Personnel potentially unable to work because the maximum exposures for the month or or year have been met. Severity Some personnel may need to work at less risky sites at the mine for the remainder of the period (a month or a year) Duration Permanent. Beyond closure. Long term. Localised - Within the site boundary. During transportation (lowest risk to public) and Spatial Scale temporary storage at Walvis Bay Harbour Probability Definite and continuous Mitigation Severity Duration Spatial Scale Consequence Probability of Occurrence Significance Unmitigated H H L H H H Significance of Mitigations to reduce exposure to health and safety risks for personnel are imperative. Consequence Prevention The removal of all hazards or risks will not be possible. It is not possible to prevent all incidents from occurring completely. An accident is an unplanned incident though it could have been foreseen if the necessary precautions had been taken. Not all hazards can be removed but the risk it presents can be lowered. An integrated health and safety management system acts as a monitoring tool and mitigating tool to reduce the risks. Typical mitigating measures within the health and safety management systems are:- ➢ Draw up operational procedure manuals ➢ Provide health and safety awareness and radiation training ➢ Establish practical standard housekeeping rules ➢ Colour code certain areas, equipment and substances to thereby classifying the risks. ➢ Provide signage for personal protective equipment (e.g. protective clothing like safety boots and hard hats) ➢ Institute safe working procedures and require permits to work ➢ Devise and implement emergency response plans ➢ Close coordination with the traffic authorities to ensure road safety signs are strategically placed and ensure all employee drivers are well trained ➢ Provide easy access to Material Safety Data Sheets (MSDS) ➢ Provide first aid treatment and training Mitigation Action ➢ Devise emergency medical procedures for all eventualities ➢ Undertake daily safety reminders and/or drills ➢ Establish regulations for handling fuel The Fuel storage and handling MSDS gives health related medical responses for personnel assisting staff who are exposed to the fuels. Procedures for dealing with injuries or accidents must be in place and all contact details for emergency personnel must be available. This list is not comprehensive and could be supplemented substantially by the Health & Safety Manager With respect to radiation exposure the following mitigations and monitoring are either mandatory by law or recommended: ➢ Annual medical assessment – apart from the normal checks, employees’ white blood cell count could be tested to assess the potential effect of radiation exposure. ➢ Personnel working in the higher risk area should wear a passive sensor that can be analysed at the laboratory to provide monthly records of radiation exposure; ➢ PPE – dust masks are worn by all employees exposed to dust. The type used is FFP3; ➢ Ideally the higher risk ground surfaces should be watered or chemically bound to supress dust billowing;

112

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

➢ Ideally at transfer points on conveyor belts and at crusher bins mist sprays should be installed; ➢ The networks of dust fall-out sampling points should be in place and monitoring results direct further decisions for planning mitigation depending on the spatial extent of any high levels of atmospheric radioactive particulates. ➢ Devices for monitoring the radiation emitted from all potential sources must be purchased and a regular monitoring programme be carried out and records kept for reporting purposes. A procedure manual must be drafted that is based on the industry standards and laws and regulations that are implemented by the MME and Ministry of Labour.

Mitigation Severity Duration Spatial Scale Consequence Probability of Occurrence Significance Mitigated L L L L L L Significance of If all the mitigations listed are implemented, then the significance will be maintained at low. Consequence The EAP is quite confident that the mitigations will result in low significance. It is imperative that continuous training and medical monitoring of personnel at the regionally (SADC region) recommended frequency. The regionally (SADC region) accepted levels of radiation exposure Confidence Level must be monitored and maintained. The only point where mitigation may be insufficient is with dust suppression due to the measures in place for limiting water use Table 22. Visual Impacts Impact Event Changes to the aesthetic appeal of the area due to presence of people, vehicles and machinery. Visible changes to habitats due to human activities. Description The experience of enjoying the landscape free of human activities is considered highly desirable. Intrusions into the current scenery may be unwelcomed. The mine site is remote and no main tourism routes pass through this valley. Residents within a 5 km radius are few. Impact on visual resources would be considered unfavourable if the landscape was significantly degraded or modified. The presence of mine personnel, vehicles and other equipment may reduce the aesthetic appeal of the area. The position of WRDs and a processing plant are key issues with regards this impact. The initial location and extent of the accessory works area has been amended so that the new site is not visible to the people stayig in Oroutumba. . The new quarries will not be visible to residents or tourists. Nature Negative Phases during which traffic, infrastructure and dust plumes which potentially play a role in Phases visual nuisances are highlighted below; Significance assessment was carried out on the operational phase which presents the long-term risk. Construction Phase Operational Phase Decommissioning Phase Post Closure Cranes used to build mine Processing plant Dismantling infrastructure Barren mountain slopes and infrastructure infrastructure and Traffic with cranes quarry scarring Additional traffic on the Processing plant, ore haulage Denuded mountain slopes district road and mine and blasting creating dust and open quarry not access roads plumes revegetated Dust plumes caused by Bare slopes, waste rock Demolishing buildings mobile equipment dumps, topsoil stockpiles causing dust plumes operating at the mine Moderate / measurable deterioration. Recommended level will occasionally be violated. Widespread complaints. Noticeable loss of resources. Severity It is a remote area off the main tourism route. Only 26 residents stay within 500m of the new processing area.

113

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Reversible over time. Life of the project. Medium term Duration (Except for the quarries which will remain visible for the long term. Fairly widespread – Beyond the site boundary. Localised at best. Though this does depend on Spatial Scale mobility of particles and prevailing weather conditions. The setting is rural and the only receptors currently are a a few residents (26 at the time of the social survey). Definite (in terms of dust plume creation from blasting) and continuous (in terms of the barren Probability mountain slopes until revegetated during post closure) Mitigation Severity Duration Spatial Scale Consequence Probability of Occurrence Significance Unmitigated M M M M M M The two aspects for visual impact are under consideration: 1. Unless it is mitigated the generation of dust should have a moderate influence on the decision to carry out the activity or not. However, natural weather conditions can also create very dusty atmospheric conditions. The mining and processing activities on site will contribute to local atmospheric dust levels and will potentially affect the visual experience Significance of of the people staying nearby. Those communities staying along the transport route are Consequence affected by other road users too, so this aspect is a cumulative impact. This latter aspect is considered a minor aspect and temporary in nature. The nearby residents (26) could be relocated to a more favourable location. 2. The aesthetic changes to the landscape can be mitigated for all phases of the mining project. Alternatives have been considered which will reduce the visual impact of the mine on any who pass through the area. 1. Dust creation cannot be prevented completely. Water is normally used to suppress dust on the roads. Blasting will be intermittent, and the plume will dissipate fairly rapidly. 2. The bare slopes cannot be avoided in the medium term and the quarries will be a Prevention permanent feature of the mining area. For operations to continue, personnel, vehicles and machinery will operate within the area for the duration of the project. It is not possible to operate and have no visual presence. Best practice Methodologies for operations will be employed. These may include the following: ➢ Existing roads and tracks are used to access the mine site. ➢ Dust suppression using water will most likely not be practical due to the non- sustainability of ground water usage. ➢ Product transport should either be containerised or at least installed with covers. ➢ Careful planning to avoid disturbing significant floral and faunal habitats when accessing the mining site ➢ Training personnel regarding the visible signs of faunal and floral biodiversity and the avoidance of habitat disturbance. ➢ Minimise the footprint of personnel, vehicles and machinery ➢ Rehabilitate habitats through the removal of obvious signs of human presence. Mitigation Action ➢ Regular removal of waste on a daily basis and disposal of waste in the appropriate manner. ➢ Removal of machinery from the mining sites if periods of inactivity are prolonged. ➢ If lighting is required at night, lights need to be strictly controlled and fixtures should be low-glare lighting with downward facing directed beams (except for quarry walls) ➢ Constructed structures should have natural colours so that they can blend in with the surrounding environment.

Often, the sites that are disturbed and rehabilitated at least from an aesthetic perspective will in time be recolonized by both plants and animals. The aim is to minimise the footprint so as to achieve the least impact due to anthropogenic influence. With respect to this the following has been considered: ➢ A reduction in the size or number of the WRDs.

114

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

➢ Location and design of WRDs to make them inobtrusive. ➢ Landscaping of quarry sites to reduce visual impact. Mitigation Severity Duration Spatial Scale Consequence Probability of Occurrence Significance Mitigated L M L L L L The dust suppression techniques if applied diligently and consistently will result in a medium significance visual impact for the residents in the immediate vicinity because dust from heavy Significance of traffic on the main dirt road will not be mitigated except by reducing travelling speeds. Consequence Additionally, the visual alteration of the mountain slopes cannot be mitigated until mine closure when at that time the quarry will remain a visual reminder of the once active mine. High, provided management implements the mitigation action and the company provides the necessary financial support to implement the changes required. A commitment to Confidence Level rehabilitating the denuded slopes and waste rock dump with the stockpiled topsoil will need to be done where practical and necessary.

115

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Table 23. Land Use Impact Impact Event Herders could potentially experience restrictions to their grazing areas Description The mining area is situated on land belonging to the government of Namibia granted to rural people in the form of communal land. The mining areas fall within the Kunene River Conservancy. The mining area falls within the Epupa Constituency but falls under the stewardship of Okangwati’s rural constituency councilor. The community has grazing rights to the area. The leaders of the community request that the area is kept safe for shepherd boys and their livestock. Th TSF may need to be fenced off to insure, the public safety. The community has many needs and request was made that the proponent consider social responsibility projects to uplift the community. Initially, the well in the Ondoto river will be shared as it has been since the sodalite mining began decades ago. Nature Negative Phases during which potential conflicts may apply are highlighted below; Significance Phases assessment was carried out on the operational phase. However, the long-term presence of quarries pose a safety risk. This is included in the assessment. Construction Phase Operational Phase Decommissioning Phase Post Closure Access to site Access to site Access to site Access to site Access to groundwater Access to groundwater Access to groundwater Public safety resources / boreholes resources / boreholes resources / boreholes Public safety Public safety Public safety Alternative uses for pit Asset security Asset security Asset security Waste management Waste management Waste management Moderate / measurable deterioration (discomfort). Recommended level will occasionally be violated. Widespread complaints. Noticeable loss of resources. Severity Herders’ area for grazing will be reduced marginally.. Public safety must prevail and access must be temporarily prohibited during blasting. Duration Reversible over time. Life of the project. Medium term (except quarry which is long term) Spatial Scale Localised. Within accessory works area and 500m boundaries around the quarries. Probability Definite / continuous Mitigation Severity Duration Spatial Scale Consequence Probability of Occurrence Significance Unmitigated M M L M H M Significance of Mitigations to ensure no conflicts with landowners occur will be necessary. Consequence It is not possible to prevent all conflicts. Any unforeseen issues will be mitigated through the Prevention various mechanisms stipulated in the EMP The EMA requires that permission be provided by the competent authorities for the listed activity. The EIA has facilitated a transparent process by which concerns were raised. The PPP has ensured that all stakeholders have been informed. The proponent is subservient to the conditions laid down by the guidelines / conditions and the law that upholds it. The implementation of the mining programme will be in accordance with the approved Environmental Management Plan (EMP). The draft EMP can be found in Appendix M. Mitigation Action The following mechanisms should be included in the environmental management system: ➢ Correspondence and agreements - document filing system ➢ Review memoranda of understanding annually ➢ Keep complaints register up to date ➢ Update stakeholder register regularly ➢ Engage land users regularly to maintain open channels of communication

116

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

➢ Fence off mining areas to increase public safety where necessary The Life of Mine is predicted to be 25 years. This represents a medium period compared to other larger mining operations at other mine sites. Depending on the management approach and decisions to allow access to grazing during no blasting periods and land markers or fences restricting access for safety and security the footprint and impact on normal usage of the area could be kept to a minimum thereby keeping the spatial extent localised. The merits of relocating the nearby 26 residents to ensure no residents live within 1km of the new processing plant. Mitigation Severity Duration Spatial Scale Consequence Probability of Occurrence Significance Mitigated L M L L L L Significance of Maintaining good relationships with landowners is imperative so that the severity and duration Consequence of disputes can be kept low. This will ensure the probability is low. I am confident that a well-designed and well implemented stakeholder engagement Confidence Level programme will cover the land use conflicts that could potentially arise. Table 24. Waste Impact Impact Event Waste Production Description Waste is generated during the construction, operational and decommissioning phases of the mine’s life. Waste can be classified into mineralised and non-mineralised waste. Non- mineralised waste can be classified as non-hazardous and hazardous waste. Medical waste is an additional category. 1. Non-Hazardous non-Mineralised includes: Metal cut offs, rubber, wood, product packaging, organic materials, glass, plastics, food scraps, cardboard/paper, used PPE, etc. 2. Hazardous non-mineralised: Printer cartridges, sewerage, batteries, hydrocarbons (oils, grease), fluorescent, etc. 3. Medical waste: Syringes, material with blood stains, bandages, etc. 4. Mineral waste includes: waste rock, tailings from mineral processing, rejects from beneficiation or concentration of other minerals, refinery or processing discards and sludges, smelter and other furnace slags, ashes, etc. (not all apply to this site but provided as examples) Nature Negative Phases during which waste will be produced are highlighted below; Significance assessment Phases was carried out on the operational phase which presents a longterm risk. Receptors potentially affected by waste are listed. Construction Phase Operational Phase Decommissioning Phase Post Closure Company personnel health Company personnel health Company personnel health General public health General public health General public health General public health Groundwater Groundwater Groundwater Groundwater Biodiversity Biodiversity Biodiversity Biodiversity Soil Soil Soil Soil Atmosphere - dust and other volatiles emitted from waste Atmosphere Atmosphere Atmosphere are covered under air quality impacts but there is some overlap with waste management risks Moderate / measurable deterioration (discomfort). Recommended level will occasionally be Severity violated. Widespread complaints. Noticeable loss of resources. Duration Reversible over time. Life of the project. Medium term Spatial Scale Fairly widespread – Beyond the site boundary. Localised at best. Probability Definite / continuous

117

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Mitigation Severity Duration Spatial Scale Consequence Probability of Occurrence Significance Unmitigated M M M M H M Significance of The mining activities will generate waste. Preventative and Mitigating mechanisms are Consequence imperative. Some waste products of categories 1-3 that can potentially impact the listed receptors can be managed to prevent impacts. Actions and company commitments that can prevent the impacts include the following: ➢ A waste management procedure should cover recycling, re-use, storage, handling, Prevention transportation, and disposal ➢ Collection and disposal of waste must be effective enough to not impact any of the receptors ➢ If waste must be stored and separated on site then the activities must take place on sealed surfaces, within bunds and fenced areas, and made ready for transport offsite by packaging the waste in sealed containers Where waste product impacts on the receptors cannot be prevented the preventative measures above should still be employed to mitigate or reduce the impacts. Mitigations for the various receptors include the following: ➢ Personal protection equipment (PPE) can protect personnel from exposure to disease or toxic chemicals ➢ Awareness training for company personnel and the general public will inform them of those wastes that may cause harm, pollute the soil, groundwater or air (if particulate) ➢ Some wastes are dangerous to fauna and flora; Animals should not be able to access the waste management area; waste must be contained so that it cannot enter the naturally vegetated areas beyond the accessory works area. ➢ Containerisation of highly volatile wastes should be actioned to reduce emissions but not so effectively that creates explosive risks if pressures build up. The latter may occur if the containers are stored outside in the heat of the sun. A waste management programme as outlined in the EMP should keep records in the form of an inventory of waste products collected, sorted, stored, recycled, reused or disposed. Certificates for disposal of hazardous waste should be filed. The mineral waste (category 4 above) will most likely only be waste rock and process tailings that cannot be processed for product. This waste rock will be dumped or stockpiled on site or alongside the new processing plant nd could be used in the rehabilitation during Mitigation Action decommissioning phase. The health risks associated with the process tailings is discussed under the health impacts above. Sewerage created at the camp or management offices either needs to be deposited directly into approved and permitted French drains or removed offsite. If the latter is to be done then sealed sewerage tanks are required. The regulations under the Water Resource Management Act need to be consulted with regards to the erection of French drains near water courses. They cannot to be constructed within 100m of the banks of a water course. Storage of hazardous liquid waste must by law follow industry standards. These standards will be communicated in fuller details by the fuel supplier. Ideally, self bunded containers should be brought to site and placed upon sealed surfaces with waste collection sumps. Fuel collection should be carried out upon the same sealed surface with slopes for runoff into the sumps. At the mining claim itself a similar bunded surface must be constructed where fuel from a bowser can be transferred to the mobile plant. An oil water separator and wash bay could be constructed in conjunction with fuel dispensing to reduce costs and the concretised footprint. Regardless of this the oil water separator is a requirement to ensure hydrocarbons do not enter the environment indiscriminately. The mobile plant workshop also needs to be constructed on a sealed surface and have liquid waste sumps so that spills can be collected and removed from site on a regular basis. A sealed waste oil contain should be constructed at the vehicle workshop. Regular removal of oil to recyclers is advised. All hazardous liquid waste should be stored on sealed surfaces. If the mitigation hierarchy is followed, rehabilitation may or may not be required. Should an Rehabilitation accident occur during the process of collection, storage or disposal of waste and no mitigation

118

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

be actioned then one of the receptors may be impacted. Consequently, the following examples of rehabilitation may be required: ➢ A person who is exposed to disease (bacteria from organic waste) or toxic waste (mineral or non-mineral), which results in harm, will need medical attention ➢ Soil which is contaminated by used hydrocarbons needs to be relocated to a remediation cell where the material after treatment, i.e. the addition of fertiliser, air and water will within a year be suitable for re-use. ➢ In the event of groundwater contamination by chemicals or hydrocarbons, the sinking of a borehole or the excavation of a pit in the vicinity of the contaminate source will allow the pumping of the groundwater into a holding dam. Through the continued pumping a cone of depression will draw the contaminated water towards the pump. The collected contaminated water can be discarded at a registered hazardous waste site or if separable the contaminant can be removed from the water before disposal. The reclaimed water could be pumped back in the pit or borehole. Mitigation Severity Duration Spatial Scale Consequence Probability of Occurrence Significance Mitigated L M L L L L Significance of If the mitigation hierarchy is followed through to rehabilitation, then the resultant Consequence consequence could be insignificant. A well designed and well implemented waste management programme will provide the Confidence Level necessary confidence that the risks to receptors will be of low significance. Table 25. Ecological & Biodiversity Impacts Impact Event Mining activities may affect biodiversity of fauna and flora directly or through habitat alteration. Description Through mining in general there is potential for impacting the diversity of species within the various habitats by reducing population numbers of certain species. Pressures on the population numbers can potentially lead to a reduction of a population within an area causing the species to no longer exist within that area. Should a species be endemic to that same area then the risk of extinction is high. Habitats can be severely altered potentially changing the type of habitat or leading to the removal of micro habitats. Specialist fauna and flora studies were commissioned for the mining claim, accessory works area and the activities therein. Site visits, species lists for the area and reference to other studies carried out nearby and elsewhere reveal that the habitats, fauna and flora present in the area are not endemic to claim and accessory works area specifically but are either common or potentially rare throughout the Kunene Region. Refer to the chapter on the fauna and flora above and to the specialist study reports in the Appendices. Three habitat types were identified in the vegetation and vertebrate studies for this project and were integrated in one combined floral and faunal classification: Mopane scrub, rocky outcrops and river/drainages. The habitats were rated as to their sensitivity, with the caveat that all habitats are sensitive to disturbance and deserving of conservation measures. A sensitivity rating was assigned based on properties of the habitat itself, including: ➢ nationally or regionally scarce habitats ➢ size of habitat, in the context of the total availability of comparable habitats in Namibia and/or the region. ➢ exceptionally high diversity and/or abundance of species ➢ high level of endemism ➢ support to species of conservation concern ➢ key ecological processes ➢ contribution to ecological functions (nutrient and energy flows) ➢ provision of critical resources ➢ restorability after disturbance Human habitation, grazing and mining activities have resulted in modified areas, some of them get severely degraded such as the rocky ridge south of ML40 and the quarry/mine sites. The village Oroutumba, located in Mopane scrub habitat adjacent to the Ondoto River, also constitutes an anthropologically modified area.

119

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

The assessment considered all project activities and how these could potentially impact the various habitats. Fauna: A key habitat in the larger woodland mosaic is the rocky outcrops habitat. The physical diversity of the hills and rocky ridges leads to a higher and more specialised biodiversity than the surrounding Mopane woodland, and it supports many species that would otherwise not be present. Seeing as mineral-bearing ore is located almost exclusively in the rocky ridges, restoration of this habitat after mining operations will not be possible to any meaningful extent. Riverine habitat has a high ecological value for all taxa, it plays a keystone role in nutrient transport, and serves as important source areas for recolonisation after operations cease. In this project footprint, the Ondoto River is considered very sensitive and apart from the proposed linear infrastructure, no development should take place there. In addition, the natural flow patterns in washes and drainages should be maintained, particularly important when designing and constructing a road network and any other linear development. Destruction of organisms and habitats and alteration of topography both have high unmitigated significance, but potentially decrease to medium significance through the application of management measures if those are carried out effectively. The cumulative nature of mining activities in the Kunene Region and in the Kaokoveld Centre of Endemism, the irreversible damage to the rocky outcrops (as the most sensitive, ecologically valuable habitat) and the persistence of the excavations after the lifespan of the mine, are three factors that decrease the likelihood of these impacts being mitigated to low significance. However, the strict implementation of mitigation measures and restoration plan can improve the situation significantly for other habitats and aspects such as the accessory works, linear infrastructure and any staff accommodation areas. A. Potential destruction of habitats and organisms could take place during construction and operations, construction and use of roads by vehicles and machinery, clearing of land, building of infrastructure, within laydown areas, around water tanks, at accommodation, around human activities, during blasting and earthmoving, around vehicle movements, and the operation of machinery. A ccumulative impact of mining in the Kunene Region, especially on ecologically valuable rocky ridges and outcrops as follows: ➢ Death of animals that are struck by earthmoving equipment, vehicles and machinery. Protected and at-risk species such as bat-eared fox, Cape fox, aardwolf and brown hyena are vulnerable to roadkill. ➢ Death of animals due to poaching. ➢ Raptors, bustards and migrating birds are vulnerable to power line impacts such as collision and electrocution. ➢ Bird nests, nesting habitats and feeding habitats are destroyed, affecting the viability of bird populations. ➢ Mammal and reptile burrows, burrow habitats and feeding habitats are destroyed, affecting the viability of the populations of these taxa. ➢ Parts of territories and home ranges are destroyed. ➢ Loss of plants and decline in habitat quality. ➢ Dust causes a decline in air quality and creates conditions for health decline in plants and animals. ➢ Noise disturbs animals and causes increase in stress. B. Potential disturbance of animals and interference with their behaviour during operations, when infrastructure and roads form obstacles to the directional movement of animals, when an increase in human and vehicle presence and movement results from mining activities, as a result of loud noises caused by blasting and the operation of heavy machinery. The potential impact could be as follows: ➢ Larger mammals and birds are the taxa most likely to be affected. ➢ The loss of migration corridors causes stress and an increased risk of death to various taxa. ➢ Birds and eggs could be poached. ➢ Animals, particularly birds, are disturbed while going about their daily activities, such as feeding, roosting and breeding. ➢ Dust creates conditions for health decline in plants and animals, and an increase in stress for animals. ➢ Noise disturbs the normal behaviour of animals, specifically mammals.

120

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

C. Potential light pollution as result of light sources that are visible outdoors in the accessory works area and in the mining area. This can impact in the following ways: ➢ Invertebrates that are attracted to the light provide an unnatural food source for taxa such as bats, geckos, nightjars and frogs. These insectivores are attracted to the food and then face conditions where they are more likely to die from causes such as collisions and predation. ➢ Invertebrates could die every night from exhaustion or predation, potentially disrupting their population numbers and causing disturbances in ecological processes. D. Alteration of topography during construction and operational phases can occur because of excavation of the ore bodies leaving a deep, open pit or several smaller quarries on the mountain. The processing plant and waste stockpiles will create large heaps of material on the surface of the landscape. This cumulative (for mining in the Kunene Region) impact acts on the level of ecosystems and could result in the following: ➢ Irreversible alteration of the ecologically valuable rocky outcrops. ➢ This impact may affect ecosystem functioning. ➢ Direct destruction of habitat and organisms (see A above). ➢ Fragmentation of habitat, leading to the loss of migration corridors for various taxa, in turn resulting in the loss of individual organisms and potentially populations. E. Groundwater drawdown - Abstraction of water from the Ondoto River and Kunene for drilling, mining, ore processing and human consumption: ➢ River vegetation is dependent on groundwater to some extent. Of particular concern are woody species in the Ondoto River, e.g. Acacia erioloba, Faidherbia albida and Ficus spp. ➢ Deterioration of the river habitat has negative impact on biodiversity outside the boundaries of the project site, specifically the Kunene River. F. Contamination of soil and water - Chemicals used in the processing of ore, e.g. radioactive thorium, escape containment and contaminate the soil, surface and groundwater ➢ Chemicals leach into soil, causing contamination of soil and eventually groundwater. ➢ Effects of chemicals are cumulative and build up in groundwater over time. ➢ Once in the groundwater, there is the potential for contamination to spread beyond site boundaries. The Kunene River is an internationally important ecological feature that could potentially be directly affected. ➢ Birds, mammals and reptiles are attracted by an unnatural source of water (open water body) and either drown or ingest contaminated water. G. Impacts associated with accommodation of staff – During construction, operational and closure phases, vehicles can cause death of organisms, staff could be involved in poaching and plant collection, cooking and lighting practices cause fires, water use in an arid zone with few resources, poor sewerage practices and from cooking and cleaning cause oil spillage. ➢ Direct destruction of organisms and habitat. ➢ Oil spills and sewerage contaminate soil and water. ➢ Fires destroy habitats and cause death of animals. Flora: The habitats and flora are either common throughout the Kaokoland and if restricted in distribution or to micro habitats, they do occur outside the planned mining areas. Riverine and drainage habitats present a high ecological value for most taxa and are considered very sensitive. Blocking of surface and/or groundwater flow will result in loss of perennial plant species and a reduction in the resources, such as food, shelter and soil stabilisation for burrows that they represent to other trophic groups. The rocky outcrops present both abundance and richness of plants that are much higher than those of the surrounding scrubland, contributing to the ecological value of this habitat. The location of the study area in the foothills of the Zebra Mountains and in the Kaokoveld centre of endemism, a biogeographical region rich in range-restricted plants and animals, further increases the sensitivity of the rocky ridges. Sodalite and the rare earth minerals are located in this habitat; it is where mining will be done and where most of the irreversible impacts (drilling, blasting and open cast mining) will take place. The largest part of ML40 consists of open Mopane scrubland. The topography is gently undulating, bisected by drainages and ridges topped with rocky outcrops. In the east and southeast of the study area the profile is flatter than in the west and northwest, where there are more and steeper rocky ridges. This habitat has been modified by human activities such as

121

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

harvesting and livestock grazing. Both these activities are current and ongoing, and the village Oroutumba is in a degraded area in Mopane scrub abutting the Ondoto River. Pipelines, powerlines, roads, and the accessory work area will all be in this habitat. Species are potentially of conservation concern when they are endemic or near endemic to Namibia, have a threatened Namibian or IUCN status, or are legally protected in Namibia. Three recently described species, Maerua sebrabergensis, Erythrococca kaokoensis and Ocimum sebrabergensis are known only from a few specimens collected in the Zebra Mountains but they are likely to be found on the ridges and rocky outcrops in ML40 as well. The fact that they were found and described as recently as 2015 and 2019 illustrates both the importance of the Kaokoveld Centre of endemism and how under-collected it is in terms of herbarium specimens. This is largely a result of the remoteness and inaccessibility of much of the region and of the Zebra Mountains specifically. The following potential aspects were assessed: A. Mining activities may affect the ecology of the flora directly through habitat alteration or destruction within the planned mining claim and accessory works area: ➢ Cumulative impact: mining in Kunene Region, especially on ecologically valuable rocky ridges and outcrops. ➢ Loss of plants and decline in habitat quality. ➢ Dust causes a decline in air quality and creates conditions for health decline in plants and animals. B. Alteration of topography – the sources of the impact during the construction and operational phases are from excavation of the orebodies that leave deep open pits caused by drilling, blasting and open cast mining and the use of equipment such as excavators, compressor driven drill rigs and cutting machines. The processing plant and mineral waste is deposited on the cleared ground. ➢ This is a cumulative impact of mining in the Kunene Region. ➢ Irreversible alteration of the ecologically valuable rocky ridges. ➢ This impact may affect ecosystems. ➢ Direct destruction of plants and habitat. ➢ Fragmentation of habitat, leading to the disruption or loss of colonisation pathways for seed dispersal, in turn resulting in the loss of individual organisms and potentially populations. C. Groundwater drawdown - Abstraction of water from the Ondoto River for drilling, mining, ore processing and human consumption. ➢ River vegetation is dependent on groundwater to some extent. Of particular concern are woody species in the Ondoto River and drainages, e.g. Acacia erioloba, Faidherbia albida and Ficus spp. ➢ Deterioration of the drainage and river habitat has negative impact on biodiversity outside the boundaries of the project site, specifically the Kunene River D. Contamination of soil and water - Chemicals used in the processing of ore, e.g. radioactive thorium, escape containment and contaminate the soil, surface and groundwater. ➢ Chemicals leach into soil, causing contamination of soil and eventually groundwater. ➢ Effects of chemicals are cumulative and build up in groundwater over time. ➢ Once in the groundwater, there is the potential for contamination to spread beyond site boundaries. The Kunene River is an internationally important ecological feature that could potentially be directly affected. Nature Negative Phases during which mining activities may impact the ecology and biodiversity through habitat Phases alteration or destruction are highlighted below; The significance assessment was carried out on both the construction and operational phases. Construction Phase Operational Phase Decommissioning Phase Post Closure Flora Flora Flora Flora Fauna Fauna Fauna Fauna Habitat Habitat Habitat Habitat Species diversity Species diversity Species diversity Species diversity Severity Moderate / measurable deterioration. Noticeable loss of resources. Duration Permanent, beyond closure, long term.

122

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Spatial Scale Localised - Within the site boundary for flora but beyond the site boundary for fauna Probability Possible/frequent Unmitigated Severity Duration Spatial Scale Consequence Probability of Occurrence Significance Fauna - A. Potential destruction of habitats and organisms Fauna A. M H M H M H Fauna – B. Potential disturbance of animals and interference with their behaviour Fauna B. M M L M H M Fauna – C. Potential light pollution as result of light sources Fauna C. M M L M H M Fauna - D. Alteration of topography Fauna D. M H M H H H Fauna - E. Groundwater drawdown Fauna E. M M M M M M Fauna - F. Contamination of soil and water Fauna F. M H M H M M Fauna - G. Impacts associated with the accommodation of staff Fauna G. M M M M M M Flora – A. Destruction of plant and habitats Flora A. H H L H H H Flora – B. Alteration of Topography Flora B. M H M H H H Flora – C. Groundwater Drawdown Flora C. M M M M M M Flora – D. Contamination of soil and water Flora D. M H M H M M The mining activities will alter the habitats that previously existed. Soil and flora will be Significance of removed. Some fauna will relocate and compete for resources in adjacent habitats, but many Consequence will be destroyed and/or affected negatively. Dust and lighting will also impact ecosystem. Mitigating & rehabilitation mechanisms are imperative. Not possible as at least many specimens of the most common flora taxa found in the district Prevention will be removed during construction activities and quarry creation. Suggested by fauna specialist: A. Destruction of organisms and their habitats: ➢ Keep the overall development footprint as small as possible. ➢ The extent and location of the construction site should be fenced and all construction activities should take place within the fence. Adherence should be strictly enforced. ➢ The location of roads, pipelines and power lines must be planned to minimise fragmentation or disturbance of habitats. Mitigation Action ➢ Anti-erosion measures must be taken where roads and tracks cross a wash or drainage. ➢ Carefully plan the placement of stockpiling construction material so as to avoid sensitive areas. ➢ Limit construction activities to daytime hours to reduce noise. ➢ Educate construction and permanent staff as to their environmental obligations. All contractors should be held responsible for transgressions and significant penalties should be levied in order to ensure compliance.

123

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

➢ Position temporary construction infrastructure (e.g. accommodation) in areas that will definitely be disturbed during operations. ➢ Erect linear structures (power lines, water pipelines) as close as possible to existing roads and tracks. Maintenance roads/tracks for linear structures should be built as close as possible to the structure and access should be limited to essential maintenance. ➢ Do not put water tanks, power pylons or any other large infrastructure in the river or washes. ➢ No sewerage overflow or French drain may be placed within 100 m of a wash or river. ➢ A vertebrate specialist should identify nests, dens and other breeding locations and demarcate them before construction so that these sites can be avoided as part of the EMP. ➢ Reptiles and amphibians that are exposed during ground clearing should be captured for translocation by a qualified expert. ➢ No collection of plants should be allowed. No fires should be allowed. ➢ A comprehensive restoration plan should be drawn up by an expert BEFORE construction commences, at least at conceptual level, and should make provision for monitoring and adaptive management as the project develops. Some rehabilitation actions should be implemented during operations in order to be effective, e.g. removal and location of topsoil; location of waste rock dumps to ensure efficient restoration later; road and pipeline locations. B. Disturbance of animals and interference with their behaviour: ➢ The extent of the operation should be clearly demarcated on site layout plans and fenced in. The nature of a fence would be informative rather than restrictive – it is to make the boundaries of the area of operations clear to staff, visitors and contractors, and to effectively control access to undeveloped areas. ➢ Areas surrounding the mine and accessory works that are not part of the demarcated development should be considered a no-development zone. ➢ No employees, visitors or machinery should be allowed in such a zone. ➢ No off-road driving should be allowed. ➢ Limit activities to day-time hours so as to reduce noise. ➢ Only controlled and contained fires should be allowed for cooking and heating purposes. Only wood collected during the clearing of areas during the construction phase should be used for firewood. ➢ The significance of this impact is somewhat decreased by the fact that human presence and human-caused disturbance in the region is already interfering with the presence and movement of many taxa, particularly large mammals. ➢ Staff and contractors should be trained in sensitive human-wildlife interaction. C. Light Pollution: Not much is known about the effect of light on populations and ecosystems and the precautionary principle is applied here. ➢ Install motion detectors to limit light use to the minimum possible. ➢ Outdoor lights should be directed downwards and not up into the sky. ➢ Use yellow or amber outdoor lights because invertebrates don't detect yellow light as well as white. ➢ Install insect screens in doors and windows located in buildings that are used at night. D. Alteration of Topography: ➢ It may not be possible to rehabilitate the site significantly, but a comprehensive restoration plan would mitigate impacts to some extent. ➢ A comprehensive restoration plan with financial mechanisms for implementation should be drawn up by an expert during the construction phase. It is possible that some mitigation measures and rehabilitation actions should be implemented during operations in order to be effective; therefore, a restoration plan should be in place at the start of operations. ➢ Implement the restoration programme as soon as possible after the impact has ceased. E. Groundwater drawdown: ➢ Monitor groundwater levels. ➢ Monitor plant and vertebrate diversity downriver from the abstraction site at a minimum of once a year. F. Contamination of Soil and Water: ➢ Containment measures should be strictly enforced to the highest existing standards. Open water structures should be sealed and provide no opportunity for either leakage or entry by animals.

124

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

➢ Constant monitoring of open bodies of water and their associated pipes, lining and covers is essential to ens.ure that there is no malfunction, tear or opening. ➢ Treatment of the final discharge of water should be in such a way as to eliminate any possibility of active chemicals entering the soil or groundwater. G. Impacts linked to accommodation of staff ➢ All inhabitants and visitors in the staff compound should receive environmental awareness training, including training on indiscriminate defecation. ➢ The staff compound should be fenced in and the only access allowed outside the fence is on the entrance road. ➢ All cleaning and washing should take place inside a designated area (e.g. kitchen, laundry) and fat traps should be installed at the drain outlet from these areas. ➢ No collection of plants or plant material should be allowed. ➢ No open fires or flames should be allowed in the staff compound. ➢ Gas cooking facilities should be provided. ➢ Lights should be solar, or generator powered - no candles or paraffin lamps. ➢ Firefighting equipment should be placed in the compound. Equipment should always be tested regularly and be in working condition. All inhabitants of the compound should be trained in the use of this equipment and know where it is. ➢ Water saving measures should be put in place, e.g. low-pressure shower heads and taps; daily checks of pipes and tanks; immediate repair of leaks. ➢ Sewerage should be of sufficient capacity for the number of people, and should be a sealed breakdown system. ➢ No sewerage overflow structure or French drain may be placed within 100 m of a wash, drainage line or river. Suggested by flora specialist: A. Habitat alteration and destruction - The spatial extent of the infrastructure should be planned to keep it as small as possible. Then when clearing areas, where possible, do not fell the larger and older trees as they act as seed (genetic stock) sources. By changing the location of the new processing plant and WRD and area of lower diversity will be impacted. However, it is not possible to reduce the impact of the quarries on the rocky habitat that harbours several protected tree species. It is recommended that a the NBRI be supported in doing a comprehensive survey of the area during the MEFT EIA review period. Roads, pipelines and power lines must be planned in order to minimise fragmentation or disturbance of habitats The following most important mitigations should be implemented: ➢ Do not put water tanks, power pylons or any other large infrastructure in the river or washes. ➢ Position temporary construction infrastructure (e.g. accommodation) in areas that will definitely be disturbed during operations. ➢ Erect linear structures (power lines, water pipelines) as close as possible to existing roads and tracks. ➢ Carefully plan the placement of stockpiling construction material so as to avoid sensitive areas. Awareness training for management & other personnel must focus on: ➢ Training of all personnel to limit the habitat alteration during the construction and operational phases of the mine ➢ Teach knowledge and understanding of the flora and its ecology The following basic rules must be adhered too: ➢ No littering ➢ Driving only on existing roads (roads created by the mine inside the mining areas. ➢ Firewood should come from trees that were felled within the cleared areas and no additional clearing for firewood should occur. A restoration plan should be drawn up by an expert BEFORE operations commences, at least at conceptual level before construction starts, and should make provision for monitoring and adaptive management as the project develops. Some rehabilitation actions should be implemented during operations to be effective, e.g. removal and location of topsoil; location of waste rock dumps to ensure efficient restoration later; road and pipeline locations. B. Alteration of Topography ➢ It may not be possible to rehabilitate the mining sites significantly, but a comprehensive restoration plan would mitigate impacts to some extent. ➢ A restoration plan should be drawn up by an expert BEFORE operation commences. ➢ Implement the restoration programme as soon as possible after the impact has ceased. 125

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

C. Groundwater drawdown ➢ Conduct a specialist hydrogeological study for the project. ➢ Monitor groundwater levels. ➢ Monitor plant and vertebrate diversity downriver from the abstraction site at a minimum once a year. ➢ Ensure sustainable water supply to the project based on the findings of the hydrogeological study. D. Contamination of soil and water ➢ Conduct specialist work on element mobilisation from the different types of ore and waste rocks. ➢ Containment measures should be strictly enforced to the highest existing standards in the mining industry. ➢ Constant monitoring of open bodies of water and their associated pipes, lining and covers is essential to ensure that there is no malfunction, tear or opening. ➢ Treatment of the final discharge of water should be in such a way as to eliminate any possibility of active chemicals entering the soil or groundwater. Rehabilitation at mine closure should be applied to the accessory works areas as defined in the project description in this flora assessment. The waste rock dump should be constructed in such a way that fits in with the surrounding physical features and so that water infiltration is maximised, and erosion minimised. These latter points will allow for natural regrowth of the vegetation on the waste rock dump. The following aspects should be considered when finalising the mine closure plan: ➢ The infrastructure removal and landscaping of the accessory works area to match as far as Rehabilitation possible the baseline conditions. ➢ Funds for rehabilitation should be set aside from the start of the operational phase. A mechanism for securing these funds should be in place during the construction phase. ➢ Reasonable and acceptable ways of rehabilitation should be implemented on an ongoing basis as well as at the time of site closure. ➢ Where the ground has been affected by spillages such hydrocarbons, these soils should be stockpiled and appropriately treated to regulate the contamination levels prior to being used for rehabilitation purposes. Mitigated Severity Duration Spatial Scale Consequence Probability of Occurrence Significance Fauna A. M M L M M M Fauna B. L L L L L L Fauna C. L M L L M L Fauna D. M M L M M M Fauna E. L M M L L L Fauna F. L L L L L L Fauna G. L L L L L L Flora A. M M L M M M Flora B. M M L M M M Flora C. L M M L L L Flora D. L L L L L L Significance of If the mitigation hierarchy is followed through to rehabilitation then the resultant consequence Consequence could be insignificant overall. A well designed and well implemented rehabilitation programme will provide the necessary confidence that the altered habitats could be rehabilitated at mine closure to a degree that the Confidence Level final footprint of the mine will be acceptable. Provided the waste rock dump is covered with the stockpiled topsoils at mine closure, natural revegetation of this area could occur in the long term. Table 26. Water Resource Impact – Over Utilisation Impact Event Mining activities may affect water resources through over utilisation

126

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Water demand for mining, processing and domestic use is estimated as 100,000 m³/year. Water will be sourced from the Ondoto River alluvium, close to Mining License 40. The sustainable yield of the Description Ondoto River is low mainly due to irregular river flow and recharge. The mine area is underlain by anorthosite that generally has poor groundwater potential. Nature Negative Phases Phases during which mining activities may impact the water resources are highlighted below. Construction Phase Operational Phase Decommissioning Phase Post Closure Alluvial aquifer of the Alluvial aquifer of the Alluvial aquifer of the Ondoto Ondoto River Ondoto River River With ceasing of abstraction, water level in the aquifer will Groundwater (via Groundwater (via borehole Groundwater (via borehole be restored with time. borehole abstraction) abstraction) abstraction) Severity Recommended water level could often be violated. Interruption of supply to mine and community. Duration Reversible over time. Spatial Scale Fairly widespread, at the mine site and neighbouring Oroutumba village. Probability Definite / continuous Spatial Probability of Mitigation Severity Duration Consequence Significance Scale Occurrence Unmitigated H M M M H H Significance of A high significance is expected if no mitigation measures are implemented. Consequence Alternative water sources to be developed such as direct intake from the Kunene River or aquifer in Prevention the bank of the Kunene River are sustainable sources. Monitoring of groundwater level and water quality should serve as early warning of overexploitation of groundwater. Limit the use of the Ondoto River alluvium to initial stages of the project. If the Ondoto River alluvial aquifer shows signs of overexploitation (drop in groundwater level and increasing salinity), the use of the resource should be stopped, and alternative sources used. If the Mitigation Action alluvium is not replenished within a year of use by the mine then the alternative water supply must be used. The community affected by the disruption of supply should be supplied from the alternative source till supply from the Ondoto River is restored. Develop the alternative source of water (Kunene river or Dwyka Aquifer) for long term use. Upon decommissioning of the mine the water levels in the hand dug well of the Onodoto river will Decommissioning resume to the levels that existed prior to use by the mine. & Rehabilitation The pipeline bringing water to the mine from the Kunene River borehole could be handed over to the community to maintain so that a more sustainable source of water could supply the community. Spatial Probability of Mitigation Severity Duration Consequence Significance Scale Occurrence Mitigated M M L M L L Provided the development of the alternative Kunene River borehole source goes ahead the impact Significance of would be low as the abstraction from the Ondoto River alluvial aquifer for mine process water could be Consequence stopped. The groundwater level will be restored with natural recharge over time. The restoration of any impact of abstraction of groundwater is dependent on groundwater Confidence Level replenishment by river flow. Arid region river flow and recharge is episodic and not often predictable. Continuous monitoring will provide feedback on the restoration of conditions of the water resource. Monitor groundwater level, gauge river level, rainfall, and abstraction daily.

Monitoring Groundwater levels monitoring is recommended for the Ondoto River hand-dug well, and also for the proposed new boreholes. Water levels are to be measured continuously, preferably by using pressure transducers.

127

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Overall the water balance of the mine and associated operations is to be monitored particularly on the following main components: ➢ Water disposal in tailings ➢ Recovered water and decrease in recovered water volumes ➢ Intake of freshwater to the mine and plant form the water supply wellfield ➢ Increase or decrease of outflow to the evaporation dam Gauging of the Ondoto River is recommended at a selected reach where the River has a straight course and flows over bedrock. The purpose of such monitoring will be to record river flow and therefore the frequency of recharge of the groundwater resource in the alluvium in case this source is tapped for mine supply. Declining water levels can be related to abstraction or lack of recharge. Monitoring is to be carried out using a pressure transducer housed in an installed perforated borehole casing. The level of the pressure transducer, cross-section and slope of the reach can be surveyed and flow rates estimated from the information. Table 27. Water Resource Impact – Potential Contamination Impact Event Mining activities may affect water resources through contamination The containment of effluent and runoff from the tailings and waste rock dump, particularly in the rainy season is of concern. Water diversion structures and a containment dam for the run-off and seepage need to be constructed with design capacity of the diversion and containment dam adequate for handling large rainfall events as experienced in this area. Potential impacts are as follows: Description ➢ Leaching of contaminants and erosion of material from the TSF and waste rock dumps into surface water channels by discarded process water and rain events are of high intensity. The leachate from the TSF and mine waste is however likely to be alkaline thus limiting the mobility of metals. ➢ Erosion of material and mobilisation of precipitates and fines is possible. ➢ Wastewater disposal reaching natural drainage Nature Negative Phases Phases during which mining activities may impact the water resources are highlighted below. Construction Phase Operational Phase Decommissioning Phase Post Closure Alluvial aquifer of the Alluvial aquifer of the Alluvial aquifer of the Ondoto Ondoto River Ondoto River River The waste rock dump and TSF will remain exposed to risk of erosion and Eroded material and Eroded material and Eroded material and fines mobilisation into surface water fines reaching the fines reaching the reaching the alluvial aquifer channels. Wastewater disposal will alluvial aquifer during alluvial aquifer during during severe rainfall events. cease. severe rainfall events. severe rainfall events. The mobilisation of material from the TSF and waste rock dump into natural water channels and Severity eventually to the Ondoto River is possible. The area experiences high intensity rainfall following extended dry periods that can mobilise sediments and material. The duration of the impact will continue through the development, operational and after Duration closure of the mine. Spatial Scale Fairly widespread, in the mine site and neighbouring village. Probability Possible / continuous Probability of Mitigation Severity Duration Spatial Scale Consequence Significance Occurrence Unmitigated M H M H M H Significance of A high significance is expected if no mitigation measures are implemented. Consequence Reclaim of process water and reuse to limit the amount of water used. Design, construction and Prevention maintenance of TSF and waste rock dumps to prevent erosion. Mitigation Action Measures to mitigate contamination of the soils, surface water and groundwater are as follows:

128

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

➢ Construction of a containment dam downstream of the processing plant, TSF, waste rock dump and other stockpiles. ➢ Evaporation of contained water that is not reused. ➢ Maintain water balance as a check on any significant water leakage from the operation. ➢ Regular inspection of TSF and WRDs. ➢ During the operation of the mine, the sediment material accumulated in the containment dam should be moved to the tailings at regular intervals so that the maximum capacity of the dam is retained and the risk of mobilising the material downstream is reduced. For the management and mitigation of possible impacts from the mining pits the following measures are recommended. ➢ The pits to a maximum depth of 40 m bgl will be above the groundwater level and no groundwater inflow is expected. ➢ Surface flow to the pits is possible and the pits should be protected against inflow of surface runoff water and discharge from the pits should be avoided. Therefore, the pits should be cordoned off with berms (1 m high) to avoid surface inflow to the pit Upon closure of the mine, the surface of the TSF should be graded to avoid ponding and encourage surface runoff thus limiting infiltration. Placement of a low permeability seal on the TSF is the preferred measure to avoid infiltration and salt accumulation in accordance with best practice measures proposed Decommissioning by the British Columbia Acid Mine Drainage Task Force (1989). For establishing such top seal, a large & Rehabilitation quantity of clay rich material would be required which may not be available locally. Alternatively, other material of good compatibility or low permeability such as compacted calcrete can be used. On closure the pits should be cordoned off with berms to avoid and prevent access to the sites by animals and humans. Probability of Mitigation Severity Duration Spatial Scale Consequence Significance Occurrence Mitigated M L L M L L The possibility of wastewater, leachate and eroded material reaching the natural river channels is Significance of significantly reduced by the construction of a containment dam. The overall risk of leaching of metals Consequence will be low due to the alkaline nature of the tailings. Continuous monitoring and implementation of mitigation measures will significantly reduce the Confidence Level probability of waste material reaching the downstream natural drainage channels. Monitor field water quality parameters of downstream aquifer, seepage (TSF, waste dumps, containment dam); quarterly sampling and analyses The following recommendations are made for the water quality monitoring. ➢ Water quality monitoring will include the following well head parameters for all water points. Well head chemistry parameters would include pH, EC, temperature, and alkalinity. Monitoring will be carried out in-house at one-month intervals. ➢ The above parameters will be monitored also on the ponding on the storage /evaporation dam and outflow, if any, from the tailings and waste rock dumps. Monitoring ➢ Quarterly sampling and analyses of water chemistry is to be done during the initial year of operation from the supply boreholes, storage / evaporation dam, the Ondoto hand-dug well and any water point established in the future downslope of the mine (north). The parameters will include major ions, minor and trace ions analysed during the project (Appendix B of the Water Study Report). ➢ Reassessment of sampling parameters and frequency of the sampling is recommended after 1 year of operation.

129

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Table 28. Socio-Economic Impact Impact Event Positive aspect of sustaining employment in the sector. Description The mining to be carried out at ML40 Sodalite Mine will employ about 50 (including haulage truck drivers) personnel to be employed by the contractor to manage the excavation, crushing, milling, screening and transportation processes. A security team of 3 personnel will also be employed. The baseline survey showed that in the immediate (radius of 1km) surrounding area only 26 persons reside. Herders use the area for grazing their livestock. The negative social impact is deemed negligible and the positive aspects of the mine on the economic benefits outweigh any negative aspects. Nature Positive Phases during which mining activities may contribute to the local economy are highlighted Phases below; The significance assessment was carried out on the operational phase which represents the longest term when benefits are greater. Construction Phase Operational Phase Decommissioning Phase Post Closure Construction personnel Operational personnel Demolition personnel Security personnel Security personnel Security personnel No employment Support services Support services Support services Substantial improvement. Will be within or better than the recommended level. Favourable Severity publicity. Duration Reversible over time. Life of the project. Medium term Spatial Scale Fairly widespread – Beyond the site boundary. Local Probability Possible/ frequent Mitigation Severity Duration Spatial Scale Consequence Probability of Occurrence Significance Unmitigated M+ M+ M+ M+ M+ M+ Significance of A medium positive significance is expected. Consequence Economic benefits could be prevented locally if no residents are employed and all materials and equipment is imported from other towns in the region and beyond. Actions that will prevent the positive impact of employment creation for this project would be Prevention the no go alternative due to either a fatal flaw from socio-economic or biodiversity impacts being of high significance. Retrenchment of permanently employed can be avoided by diversifying the business options in the construction industry. Where possible personnel should be hired from the local resident pool. At least this should apply to the unskilled vacancies. The company could start social responsibility projects to uplift the areas health and educational Mitigation Action needs. Possible need to relocate the nearby 26 residents would be a negative impact but this depends on the opportunities afforded the people after their relocation. Mitigation Severity Duration Spatial Scale Consequence Probability of Occurrence Significance Mitigated M+ M+ M+ M+ H+ M+ Significance of A medium positive significance is expected. Consequence Provided local residents are hired then one can be more confident in achieving the medium Confidence Level significance. Through meaningful permanent employment economic development can be secured for all concerned.

130

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Table 29. Traffic Impacts Impact Event Transporting bulk manganese by trucks (PBS) along national roads Description The potential impacts of the haulage of bulk product can be categorised in terms of public safety and capacity of the road to handle 67 tonne vehicles. For public safety the proponent or contractor must abide by the rules and regulations that are enforced by the Roads Authority. The vehicles need to be routinely checked for road worthiness and the containment of the goods needs to be such that no harm may come to the public and other road users during the transit from the mine to the port of Walvis Bay. No product may be strewn along the roadside as part of the normal transit. Covers over bulk transporters must always be adequate. Drivers must always follow the rules of the road. Additionally, the route provides for adequate visibility on hills and turns and that the road will always be safe for two-way traffic except where single traffic bridges exist. The capacity of the whole road should be such that the surface is not damaged as a result of the load beyond the normal wear and that the bridges to be crossed have the integrity to handle multiple crossings at the frequency expected. A route might need to be altered should a bridge not be sufficiently strong to handle the 67 tonne laden vehicle. Additionally the frequency of trucks per day is such that it does not exceed the threshold that was originally designed for the route. A planned 5 trucks per day are expected to travel along either of the possible routes. The preferred shorter route is less frequented by traffic but currently has long stretches of gravel road. The PBS option will mean slower travel and less impact on the road surface. Thus the gravel road sections are expected to be less dusty due to slower travelling speeds and will not be negatively impacted by the 67 tonne laden vehicles. A bridge assessment has confirmed that the bridges along the shorter gravel route are structurally sound and can handle the larger payload. Nature Negative Significance assessment was carried out on the operational phase which represents the period Phases the road, road users and the public are exposed to the hazard. Construction Phase Operational Phase Decommissioning Phase Post Closure Public safety – pedestrians and road users Road design – surface integrity and bridge strength Regulations – mass of vehicles when fully laden and permits Severity Moderate / measurable deterioration. Noticeable loss of resources. Duration Medium term. Life of Mine. Spatial Scale Widespread – Far beyond site boundary. National Probability Possible/ frequent Mitigation Severity Duration Spatial Scale Consequence Probability of Occurrence Significance Unmitigated M M H H M H Significance of Mitigations to reduce risks to Public Safety are imperative. Consequence The removal of all hazards will not be possible as they are beyond the control of the truck Prevention driver. As far as public safety is concerned it is not possible to prevent all incidents from occurring completely but the probability can be reduced if the following aspects are considered:- Mitigation Action ➢ Draw up operational procedure manual ➢ Provide road safety awareness training

131

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

➢ Establish specific rules for driving including travelling speed and rest times. ➢ Devise and implement emergency response plans ➢ Close coordination with the traffic authorities to ensure road safety signs are strategically placed and ensure all employee drivers are well trained ➢ Provide easy access to product Material Safety Data Sheets (MSDS) for drivers ➢ Provide first aid training ➢ Devise emergency medical procedures for all eventualities ➢ Undertake daily safety reminders and/or drills ➢ Establish regulations for handling fuel ➢ Establish and implement measures to exclude discharge of product particulates during travel As far as capacity is concerned the frequency and of trucks must be maintained at the stated daily rate and there should be at least 2 km travelling distance between trucks. Only one truck should travel over a bridge at any one time. Avoidance of travelling during peak times on busy sections of road should be practiced. The capacity of the road to handle the additional 5 trucks per day is within the road design. Mitigation Severity Duration Spatial Scale Consequence Probability of Occurrence Significance Mitigated M M H M L M Significance of If all the mitigations listed are implemented, then the significance will be maintained at Consequence medium. The significance would be lower had the spatial extent not been over such a long stretch of Confidence Level road. Table 30. Product Handling & Storage Impacts Impact Event Bulk storage and handling of product at Walvis Bay Port

Description The management of the product at the Port of Walvis Bay involves various hazards that can have an impact on the Port functioning, third parties and the proponent. The potential impacts on human health and safety resulting from activities at the port could include occupational accidents and injuries, vehicle accidents, exposure to weather extremes, trips and fall on uneven terrain, adverse health effects from dust generation and emissions, and contact with hazardous materials. The site of storage itself needs to be safeguarded from any impacts of the product directly. Failure to store and handle the product safely at any point between the storage facility and the stowage on board the ship could have negative impacts on the other users of the port and areas they are responsible for. The proponent and contractors must follow a set of industry-specific safety and health policies at the Port. Typical operational procedures that pose risks to operational personnel are: ➢ Operating heavy machinery such as, front-end loaders, conveyors, forklifts, articulated trucks and trains during handling and transfer to ships ➢ Operating haulage trucks during offloading ➢ Prolonged proximity to and exposure to manganese particulates either inside a warehouse or around exposed stockpiles. The REE product contains a measure of radioactive thorium. Table 21 mentioned health impact of this aspect and those mitigations will apply. The carcinogenic nature of the product means that precautions must be made in terms of concentration of the radioactive element, the period of exposure and the proximity to the product. Exposure is through inhalation (if product particulates are exposed), oral, and dermal contact. The other products are not as dangerous but manifest normal risks such as dust inhalation. Nature Negative The significance assessment was carried out on the operations at the port. No construction Phases phase is expected.

132

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Construction Phase Operational Phase Decommissioning Phase Post Closure Receiving product from the mine in bulk or bulk bags Storage and containment of bulk bags or bulk product at . the port Transfer of the product to the vessel Severity Moderate / measurable deterioration. Noticeable loss of resources. Duration Medium term. Life of Mine.

Spatial Scale Localised - Within the site boundary. Temporary storage at Walvis Bay Harbour

Probability Definite and continuous Mitigation Severity Duration Spatial Scale Consequence Probability of Occurrence Significance Unmitigated M M L M M M Significance of Mitigations to reduce exposure to health and safety risks for personnel are imperative. Consequence The removal of hazards or risks will possibly prevent accidents from occurring. However, it is Prevention not possible to remove all risks. It is not possible to prevent all incidents from occurring completely. An accident is an unplanned incident though it could have been foreseen if the necessary precautions had been taken. Not all hazards can be removed but the risk it presents can be lowered. An integrated health and safety management system acts as a monitoring tool and mitigating tool to reduce the risks. Typical mitigating measures within the health and safety management systems are:- ➢ Draw up operational procedure manuals ➢ Provide health and safety awareness training ➢ Establish practical standard housekeeping rules ➢ Colour code certain areas, equipment and substances to thereby classifying the risks. ➢ Provide signage for personal protective equipment (e.g. protective clothing like safety boots and hard hats) ➢ Institute safe working procedures and require permits to work ➢ Devise and implement emergency response plans ➢ Close coordination with the traffic authorities to ensure road safety signs are Mitigation Action strategically placed and ensure all employee drivers are well trained ➢ Provide easy access to Material Safety Data Sheets (MSDS) ➢ Provide first aid treatment and training ➢ Devise emergency medical procedures for all eventualities ➢ Undertake daily safety reminders and/or drills ➢ Establish regulations for handling the product ➢ Establish monitoring points for particulate contamination around the storage facility. Procedures for dealing with injuries or accidents must be in place and all contact details for emergency personnel must be available. This list is not comprehensive and could be supplemented substantially by the Health & Safety Manager With respect radiation exposure the following mitigations and monitoring are either mandatory by law or recommended: ➢ Annual medical assessment

133

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

➢ PPE – dust masks are worn by all employees exposed to manganese dust. The type used is FFP3; ➢ Rules applicable to the Port Authority must be applied. ➢ Equipment for measuring radiation emissions need to be purchased and personnel trained to use them. Mitigation Severity Duration Spatial Scale Consequence Probability of Occurrence Significance Mitigated L L L L L L Significance of If all the mitigations listed are implemented, then the significance will be maintained at low. Consequence The EAP is quite confident that the mitigations will result in low significance. Continuous training and medical monitoring of personnel and the regionally (SADC region) recommended frequency is imperative. The regionally (SADC region) accepted levels of radiation exposure in Confidence Level employees must be monitored and maintained. The port authority will place the onus on the proponent to provide proof that the source of pollutants is not from the site of proponent. Table 31. Heritage Impacts Impact Event Heritage related impacts. Description Kaokoland is a special place and it is recognised for its world heritage and for the people who continue to live off the land there. It is expected that the area has important sites of national importance from a historical and pre-historic perspective. The siting of graves, ritual sites, middens and other such important heritage aspects within the mining area could mean that specific areas within ML40 need to be kept pristine for further study. The site visit with traditional leaders did not yield any sites of significant importance. Appendix N constitutes a record of the survey of the mining licence area carried out with traditional leaders. No sites of importance were recorded. If any unknown sites were damaged in any way it would be considered a heritage impact and depending on the importance of the site result in a great loss were it damaged by mining. Nature Negative Phases during which the significance assessment was carried out is highlighted in green. It is Phases the various personnel who could potential come across as yet to be documented find. Construction Phase Operational Phase Decommissioning Phase Post Closure Construction personnel Operational personnel Security personnel Security personnel Residents Residents Severity undetermined as yet Duration Not reversible over time. long term Spatial Scale Localised to within the mining licences. Probability Possible because no records known to proponent Mitigation Severity Duration Spatial Scale Consequence Probability of Occurrence Significance Unmitigated H H L H L M Significance of A medium significance is expected. Consequence Well trained staff who know what to look for during the construction and operational phases Prevention could prevent any destruction of important sites. Submit the the survey report to the Heritage council. The survey was undertaken of the area with the help of local leaders to identify any place of importance before any construction starts. Mitigation Action Submit this survey report to apply for the necessary clearance from the Heritage Council to be able to start construction on the planned site.

134

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Should anything come up during construction or operations then work should stop and the local police should be informed. A member of the heritage council would need to assess the importance of the chance find and provide the necessary permission to continue with works at that specific site. Mitigation Severity Duration Spatial Scale Consequence Probability of Occurrence Significance Mitigated L H L M L L Significance of A low significance is expected. Consequence Provided all personnel are trained in the procedure of chance finds the destruction of Confidence Level anything important could be prevented. Table 32. Post Mining Legacy Impact Impact Event Abandonment of the mining site potentially exposes public and wildlife to hazards

Description When a mining area is abandoned the infrastructure and altered landscape can affect the safe access of wildlife and general public if not rehabilitated. The altered habitat may or may not promote the re-establishment of organisms once found there. Visual rehabilitation to the original state is not always practical due to economic factors. Nature Negative Phases during which decommissioning, and mine closure may impact public safety, future Phases ecosystem functioning for domestic livestock and wildlife, economic stability and social health, and asset security. The significance assessment is carried out for the post closure phase. Construction Phase Operational Phase Decommissioning Phase Post Closure Ecosystem functioning Ecosystem functioning Public safety Public safety Not applicable Not applicable Economic uncertainty Social challenges of Asset security unemployment Severity Substantial deterioration after mine closure with respect to aspects listed above. Duration Permanent. Beyond closure. Long term. Spatial Scale Fairly widespread – Beyond the site boundary. Local Probability Definite / continuous Mitigation Severity Duration Spatial Scale Consequence Probability of Occurrence Significance Unmitigated H H M H H H A high significance is expected if no mitigation mechanisms are implemented. This is a worst case scenario where no alternative uses of the altered habitat is considered. Significance of Consequence In terms of economic benefits lost, it is important to note that the longer the mine stays open the longer the benefit to the community which if the mine did not start up would not have been realised in the first place. The resources are finite and so decommissioning is inevitable at some point. The degree to which the impact of closure will have will depends on the mitigations that can be considered. Ecosystem functioning of the whole area cannot return to baseline conditions unless the excavated quarry is refilled and the area revegetated to baseline conditions. This is not practical Public harm can be prevented provided the area is secured and the risky hazards are Prevention inaccessible. Jobs within this sector will be lost. This cannot be prevented unless the employees move with the company to the next site. Theft and damage to equipment can be prevented during the decommissioning phase provided good security prevents any form of criminal behaviour by disgruntled employees.

135

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

Visual impacts can be mitigated through a thorough removal of all infrastructure. The reduction in the size of the mine footprint during operations and decommissioning increases the probability that more habitat will become fully functional when the mine closes. Secure fencing or other physical objects (rock piles) around any hazardous quarry pits (i.e. height risks) could prevent accidents from occurring but the permanent and visually acceptable barrier to humans and wildlife would be required to prevent injuries due to falling from heights. Access down into the pit could be allowed provided there is no risk from falling rocks. Mitigation Action The access road leading to the pit, waste rock dumps areas should be closed off to the public except to those that need access to the facilities for inspection after closure. Wherever there are safe access roads that are useable by the neighbours, these should be left. Some infrastructure could remain if alternative uses for buildings could be found. When the mine closes the losses of employment will have a negative economic effect on the livelihoods of the workers and the region. To mitigate this impact all stakeholders should be notified about the mine closure in good time.

Reasonable rehabilitation of the mine site should take place. The proponent will be responsible to put aside funds for rehabilitation. The mine closure plan with the mine rehabilitation or restoration plan should be written up during the first three years of the first environmental clearance. Rehabilitation of the abandoned mining area will amongst other things include the following: ➢ All movable assets to be removed off site ➢ All waste to be removed from site to prevent later potential excavation by people trying to recover any sort of usable scrap / materials Rehabilitation ➢ All immovable machinery to be dismantled and removed from site ➢ Possibly create shallow sloped sides of quarried areas ➢ WRD material are used in landscaping ➢ All stockpiled topsoil will be re-laid on the landscaped areas. ➢ Designed landscaped areas to be revegetated with plants from the nursery ➢ Finally, erect fencing or barriers to prevent access by public or animals to cliff faces of the quarried pits Mitigation Severity Duration Spatial Scale Consequence Probability of Occurrence Significance Mitigated L M L L L L Significance of If the mitigation hierarchy is followed through to rehabilitation, then the resultant Consequence consequence could be insignificant or at worst a low significance. A well designed and well implemented mine closure plan should provide for a low significance Confidence Level upon mine closure.

136

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

8 ENVIRONMENTAL MANAGEMENT PLAN The Environmental Management Plan (EMP) provides management options to ensure impacts of the quarry are minimised. An EMP is a tool used to take pro-active action by addressing potential problems before they occur. This should limit the corrective measures needed, although additional mitigation measures might be included if necessary. The draft EMP is found in Appendix M. The objectives of the EMP are: ➢ to include all components of the operations of the project; ➢ to prescribe the best practicable control methods to lessen the environmental impacts associated with the operations of the project; ➢ to monitor and audit the performance of operational personnel in applying such controls; and ➢ to ensure that appropriate environmental training is provided to responsible operational personnel. The EMP acts as a stand-alone document, which can be used during the various phases (construction, operational and decommissioning) of the facility. All personnel taking part in the extraction operations should be made aware of the contents of the EMP, to plan the relevant operations accordingly and in an environmentally sound manner. The EMP outlines 9 environmental management programmes which are to be used for all phases of the mining activities. Monitoring recommendations are included in the EMP. The programmes listed and described in the EMP are: 1. Air quality Management Programme 2. Noise Management Programme 3. Health & safety Management Programme (includes Security) 4. Visual Management Programme 5. Stakeholder Communication Management Programme (include socio-economic aspects) 6. Waste Management Programme 7. Ecology Management Programme 8. Water Resource Management Programme 9. Mine Closure & Rehabilitation Management Programme The proponent could implement an Environmental Management System (EMS) to manage these 9 programmes. However, a good EMS goes beyond mere implementation of the EMP. An EMS is internationally recognized as best practice that will ensure ongoing incorporation of environmental constraints. At the heart of an EMS is the concept of continual improvement of environmental performance with resulting increases in operational efficiency, financial savings and reduction in environmental, health and safety risks. An effective EMS would need to include the following elements: ➢ A stated environmental policy which sets the desired level of environmental performance; ➢ An environmental legal register; ➢ An institutional structure which sets out the responsibility, authority, lines of communication and resources needed to implement the EMS; ➢ Identification of environmental, safety and health training needs; ➢ Implementation of the EMP’s Environmental programmes; ➢ Stipulated environmental objectives and targets to be MET, and work instructions and controls to be applied in order to achieve compliance with the environmental policy;

137

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

➢ Periodic (internal and external) audits and reviews of environmental performance and the effectiveness of the EMP and EMS; ➢ Complete development of a Mine Closure Plan submitted and approved by MET and MME.

138

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

9 CONCLUSIONS & RECOMMENDATIONS The proponent will contribute locally to employment opportunities for both locals and contractors. Skills transfer and training would develop the local workforce during both the construction and operational phases. Social responsibility projects need to be identified by the proponent to help the rural communities develop their skills or provide for their health of education. The EMP should be used as an on-site reference document for the design, construction, operations and decommissioning of the mine and asociciated works. Parties responsible for transgressing the EMP should be held responsible for any rehabilitation that may need to be undertaken. The proponent could use an in-house Health, Safety, Security and Environment Management System in conjunction with the EMP and its management programmes. Personnel must be taught and understand the contents of the EMP as a minimum requirement. Best practice would be the hiring of a suitably qualified and experienced environmental control officer to implement the environmental management programmes. Alternatively, the implementing of the programmes should be delegated amongst the management personnel on and off site. The EMP requires minimum and realistic monitoring of the environmental aspects explicitly listed for each of the management programmes. Based on the information provided in this report, the EAP is confident that the identified potential impacts associated with the project can be reduced to acceptable levels. This is conditional on the implementation of all the measures (i.e. preventions, mitigations, remediations, monitoring etc.) described in the EMP.

139

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

10 REFERENCES Ashby, A., 2019. Socio-Economic Scoping Study as input to the Environmental Scoping Study, for Gecko’s Proposed Opuwo Cobalt Project, Kunene Region. Baseline Scoping Report. Liebenberg-Enslin, H., 2019. Opuwo Cobalt Project, Namibia: Air Quality Baseline Assessment. For SLR Environmental Consulting Namibia (Pty) Ltd Mendelsohn, J., Jarvis, A., Roberts, A. & Robertson, T. 2002. Atlas of Namibia. A portrait of the land and its people. David Philip Publishers, Cape Town, RSA. Olivier, 2020. Bridge Assessment Study. Structural Assessment of Six (6) Bridges Along the Kamabjab to Henties Bay Route to Accommodate Pbs Vehicle Loading as Proposed by Gecko Logistics. Potgieter, H., 2020a. Vegetation Baseline Study and Impact Assessment: ML40 Sodalite and rare earth minerals mine, Kunene Region. Potgieter, H., 2020b. Vertebrate Baseline Study and Impact Assessment: ML40 Sodalite mine, Kunene Region. Sarma, D., 202. Hydrological and Hydrogeological Assessments as Part of an Environmental Scoping Study for Mining of Blue Sodalite Dimension Stone, and Other Minerals: ML40 and Mining Claims, Kunene Region.

140

11 APPENDIX A: CURRICULUM VITAE OF ENVIRONMENTAL ASSESSMENT PRACTITIONER

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

142

12 APPENDIX B: SITE NOTICES

Ruiters Primary School - Ohandungu Notice Board – Kunene Regional Offices, Opuwo

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

144

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

145

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

146

13 APPENDIX C: PRESS NOTICES (NEWSPAPER AVERTISEMENTS)

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

148

14 APPENDIX D: BACKGROUND INFORMATION DOCUMENT

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

150

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

151

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

153

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

154

KNL of Namibia (Pty) Ltd – ML-40 Mining and Processing – April 2021

155

Public Consultation for Proposed Sodalite Mine near Otjimuhaka, Kunene Region

157 Public Consultation for Proposed Sodalite Mine near Otjimuhaka, Kunene Region

158 Public Consultation for Proposed Sodalite Mine near Otjimuhaka, Kunene Region

159 Public Consultation for Proposed Sodalite Mine near Otjimuhaka, Kunene Region

160 Public Consultation for Proposed Sodalite Mine near Otjimuhaka, Kunene Region

161 Public Consultation for Proposed Sodalite Mine near Otjimuhaka, Kunene Region

162 Public Consultation for Proposed Sodalite Mine near Otjimuhaka, Kunene Region

163 Public Consultation for Proposed Sodalite Mine near Otjimuhaka, Kunene Region

164 Public Consultation for Proposed Sodalite Mine near Otjimuhaka, Kunene Region

165 Public Consultation for Proposed Sodalite Mine near Otjimuhaka, Kunene Region

15 APPENDIX E: PUBLIC PARTICIPATION REPORT Resilient Environmental Solutions cc P. O. Box 90709, Windhoek 76 Dr Frans Indongo St, Windhoek West

Public Consultation Report for the Proposed Sodalite Mine

near Otjimuhaka, Kunene Region

3 October 2020

Proponent: KNL 166

Public Consultation for Proposed Sodalite Mine near Otjimuhaka, Kunene Region

List of Abbreviations and Acronyms

CV Curriculum Vitae

DEA Department of Environmental Affairs, MEFT

EA Environmental Assessment

EAP Environmental Assessment Practitioner

ECC Environmental Clearance Certificate

EIA Environmental Impact Assessment

EMA Environmental Management Act

EMP Environmental Management Plan

GG Government Gazette

GN Government Notice

I&AP Interested and Affected Party

MAWLR Ministry of Agriculture, Water and Land Reform

MEFT Ministry of Environment, Forestry and Tourism

MME Ministry of Mines and Energy

NORED Namibia Northern Regional Electricity Distributor

168 Public Consultation for Proposed Sodalite Mine near Otjimuhaka, Kunene Region

List of Appendices

Appendix A: Public Consultation

1st Round of Public Consultation Appendix 1: Register of Interested and Affected Parties Appendix 2: Notification emails sent to I&APs Appendix 3: Background Information Document Appendix 4: Minutes of stakeholder meetings Appendix 5: Issues and response table

169 Public Consultation for Proposed Sodalite Mine near Otjimuhaka, Kunene Region

Introduction

This brief report serves as an input to the EIA report for the proposed Sodalite mine on ML 40 near Otjimuhaka, Kunene Region. It addresses the first round of public consultations run for the EIA.

170 Public Consultation for Proposed Sodalite Mine near Otjimuhaka, Kunene Region

Public Consultation Public consultation is an important aspect of an EA process. During public consultation, potential impacts that the proposed project may have on the receiving environment, are identified. Consultation with Interested and Affected Parties (I&APs), representing both state and non-state interests, enables transparent decision-making.

This chapter describes the details of the public consultation process that was followed and the I&APs that were notified of the study being undertaken. It also includes the main issues and concerns raised during the public consultation process and comments received on the Background Information Document (BID) distributed during the first round of public consultation.

Public consultation for the purposes of this project was done as prescribed by Regulations 21 to 24 of the Environmental Impact Assessment Regulations (GN. 30 of 2012).

First Round of Public Consultation Engagement with I&APs as part of the first round of public consultation commenced in July 2020 and concluded on 28 August 2020. I&APs and authorities were given an opportunity to register and submit comments on the proposed project.

The schedule of public consultations is provided in Table 33, and further elaborated below.

Table 33. Timetable of public consultations. Date Venue Facilitator Stakeholders Confirmations, details, follow-ups

21&28 Nation- The All interested parties Advertisements in public newspapers – July wide Namibian first notice. 2020

21&28 Nation- The All interested parties Advertisements in public newspapers – July wide Republikein second notice. 2020

20 – Email Philip All pre-identified stakeholders 24 notices Hooks in Opuwo and Otjimuhaka Aug sent out GRN offices and NGOs 2020 (Appendix 1)

29 – John Pallett Telephone follow-ups with 31 identified stakeholders for July meetings in Opuwo and 2020 Otjimuhaka

Mon 3 MEFT John Pallett MEFT – Moses Areseb Send list of all stakeholders to Moses so Aug office, (Warden, Opuwo) that they can identify any gaps and let Opuwo us know. 14h30 Steve Kasaona (Ranger CBNRM, Opuwo), JP to contact:

171 Public Consultation for Proposed Sodalite Mine near Otjimuhaka, Kunene Region

Date Venue Facilitator Stakeholders Confirmations, details, follow-ups

Daniel Kafula (Director Kunene R Conservancy Chairperson, Mr CBNRM, Opuwo). Kwejo Rutjindi. 081-3471624.

Erens Kutako (Warden Regnl Okanguati Sen Game Guard Mr Services, Opuwo) Kakondo. 081-2393806.

Moses will try to secure Okanguati Chairperson Mr Tjirambi 081- Kunene Consvcy members too 2308007.

Mon 3 Courtesy JP Ms Emilia Alweendo, acting JP to send invitation to Ms Alweendo. Aug call to CRO. She will distribute to all other relevant Regional ministries in Opuwo: 16h00 Mr Johan Jantse (not sure of Council his position) office, • Min Health MoHSS Opuwo. Mr Emanuel Nafele (MURD, • Min Safety and Security Meet and Devt Planning) greet • Min Home Affairs Mr Gary Nekongo (Dep Director, MLR) • Min Works and Transport.

Mr Petrus Ashipala (Dep Ms Alweendo to notify Governor Director, Rural Services) JP to notify Ruacana Constituency Councillor (Omusati Region). Mr Shitama.

Mon 3 Hon JP Hon Muharukua confirmed he will Aug Muharukua attend Wed meeting in Otjimuhaka. Charon has been told to notify all 18h30 relevant chiefs and community leaders. He will also send out the word.

Wed 5 Otjimuhaka Charon Hon Muhurukua Charon to advertise on Mon 3 Aug on Aug Prim Katjiuongua radio. Local TAs, community leaders 14h00 School (organising and members JP to ask Hon Muhurukua to inform the meetg), relevant TAs and community leaders. Kunene River Conservancy Matjiua Hengua DoF from Okanguati – Mr (translator, Hennie Kakondo. Not sure MC), about transport. JP to help him share a lift. John Pallett (facilitator)

Thurs Boardroom John Pallett Confirmed with Mr Jantse in Regional 6 Aug of Ministry Council. of Land 14h00 JP has asked Ms Alweendo to send Reform, notification to other ministries. Opuwo

Fri 7 Any further John Pallett Aug meetings in

172 Public Consultation for Proposed Sodalite Mine near Otjimuhaka, Kunene Region

Date Venue Facilitator Stakeholders Confirmations, details, follow-ups

Opuwo as required

Fri 28 Deadline Aug for submission of comments to EAPs.

A comprehensive list of all Interested and Affected Parties (I&APs) is provided in Appendix 1. This served as the register of all people who were contacted and who participated in the consultation process.

A Background Information Document (Appendix 3) was sent out to all I&APs with an email address, as shown in the emails in Appendix 2.

In the week of the community meeting at Otjimuhaka, radio advertisements were sent out on the NBC Otjiherero channel, notifying listeners of the community meeting and inviting their participation. This was to target the many local people who do not speak or read any English or Afrikaans.

Advertisements of the public consultation process and inviting participation were placed in The Namibian and New Era newspapers on 21st and 28th July 2020.

The main sharing of information occurred at the community meeting in Otjimuhaka on Wed 5 August, and at a meeting with GRN authorities in Opuwo the following day. The minutes of these meetings are provided in Appendix 4. The community meeting was well attended with over 100 participants, and lasted over 5 hours. The meeting with regional officials was attended by representatives from three ministries/parastatals:

• Ministry of Agriculture, Water and Land Reform; • Ministry of Environment, Forestry and Tourism; • Roads Authority. Further face-to-face meetings were held on Friday 7 August with the following ministries:

• Ministry of Health and Social Security • Ministry of Works and Transport; • Ministry of Home Affairs; • Ministry of Safety and Security. The presentation that was made to Opuwo officials is provided in Appendix 5.

173 Public Consultation for Proposed Sodalite Mine near Otjimuhaka, Kunene Region

All issues and responses from the consultation meetings are clustered according to themes shown in Table 34 below. The full issues and response form is provided in Appendix 6.

Table 34. Summary of issues raised in the public consultation process.

Theme Brief summary of issues

2 Mine infrastructure, Concerns about local people being negatively impacted by eg the processes and tailings dams, dust, radiation, contamination of groundwater, and developments solid wastes.